We want to offer a bonus interest rate on a NOW account for six months if the customer has Social Security or similar benefit payments or payroll checks direct deposited to the account. If we advertise this bonus, will we have to include the bonus details and the account APY in the advertisements?
We have an application that started as an $18,000 home equity line of credit (HELOC) for home improvements. The bank counteroffered the applicant a closed end mortgage in the amount of $8,671 and they accepted that offer and their government monitoring information was then collected and disclosures were sent. Days later the applicants called back and stated after further consideration they were not comfortable with doing the closed end mortgage, which raises a couple questions: 1 – do we go back to the original request of a HELOC and deny the HELOC application for excessive LTV listing our counteroffer; or 2 – do we report the accepted closed end mortgage counteroffer as home improvements on our HMDA LAR as a withdrawn request?
I have a question concerning the Rate Lock disclosure on the Loan Estimate. If we disclose “NO” for the Rate Lock and don’t set the rate until the Closing Disclosure is provided do we have to provide a Revised Loan Estimate before the loan closing? What if the interest rate does not change from the Loan Estimate to the Closing Disclosure?
In the last Compliance Action, there was a Rate Lock disclosure Q&A. My concern is not about the meat of the question, but about a comment regarding written rate lock agreements. It stated that the rate lock must be “written” to officially lock the rate per the TRID. I cannot find where TRID says that the rate lock must be written. Can you please point me to the section or other documentation requiring written rate locks? We are internally debating the discrepancy between TRID disclosures and the HOEPA/HCML issues related to setting the final rates.
What are lenders doing when an appraisal comes in low, and a counter-offer is made to the customer? Since we are mandated to issue a new LoanEstimate within 3 days; it’s a challenge for our loan officers to get their customers to decide in 3 days whether they want to proceed with an option such as PMI, secondary financing, lower amount etc.How are other lenders handling this?
One of our lenders asked if he is able to provide yard signs to his realtor contacts to place on their listed properties for sale. I think it is a great marketing idea. The sign would state something to the effect of “Financing Available through “XYZ Bank” for qualified applicants. Please contact [loan officer name and phone number] or stop in at our ABC location to complete an application.”