Most Popular Compliance Content
Saturday and HOEPA
11/03/2003
For HOEPA loans, does Saturday count as one of the three days between disclosure and closing?
Early Disclosures on Construction Loans
11/03/2003
Our most recent compliance review said we should be sending out early disclosures for RESPA and Reg Z on construction loans. We have been making construction loans for years and this has never come up before. We don't extend permanent financing approval until processing is complete. No one else in our market is doing these disclosures either. Help!
Taxes and the GFE
11/03/2003
I have been under the impression from examiners that for any RESPA applicable loan the GFE should have the estimated property taxes and most often should be noted as POC. Is this correct? I have received some differing opinions from others that this would depend on whether or not the funds were to be escrowed or not.
Bank in Dark Ages
11/03/2003
Believe it or not, we still hand type all promissory notes and all lending documentation in our bank. I have been trying to convince the boss to move to an automated system based upon the time issue, but now am going to try from a compliance issue. I need help with my side of the argument.
Reg E Disclosure Revisited
11/03/2003
I viewed a Guru Q and A on the topic of "When to give the Reg E Disclosure," answered by Andy Zavoina. If possible, I would like additional comment on the issue of redisclosing to an existing customer that subsequently requests an access device and/or new EFT service. For example, the customer receives an EFT disclosure at account opening. One year later, the customer requests a debit card. The Commentary [205.7(a)(4)] states that redisclosure is required if the terms and conditions differ from the initial disclosure provided. If the terms and conditions have not changed from the initial disclosure, and the disclosure covered all EFT services offered, does the reg REQUIRE redisclosure? I certainly concur that to redisclose in the above example would be prudent on a riskbased standpoint, but is it required?