HOEPA Disclosure Requirements
11/11/2002
If the customer decides after closing that they want credit insurance and it now makes the loan fall into HOEPA, do you give them the disclosures after the fact?
11/11/2002
If the customer decides after closing that they want credit insurance and it now makes the loan fall into HOEPA, do you give them the disclosures after the fact?
11/11/2002
What are the regulations on charging a fee for flood certification. And can a bank charge the customer more than the bank paid for it?
11/11/2002
The following is a question from a branch: Are you aware of a checking account for real estate firms that allows them to earn interest? I have been told by one of our customers that the laws recently changed to allow for them to earn interest. In the past, I have put them in a Commercial Money Market account, but that of course restricts their withdrawals.
11/11/2002
Is it within compliance regs to put a hold on an out of state check on new customer?
11/04/2002
On a RESPA covered transaction, the lender agrees to accept a survey previously obtained by the seller. How exactly is that disclosed on the HUD-1 [survey, name of survey company, POC?] Is the dollar amount the seller paid for the survey required to be on the HUD-1 and what if the seller cannot remember how much he paid for the survey? Must the lender insist the seller provide proof the actual cost?
11/04/2002
Consumer is constructing a residence on land already owned, using consumer's own money. Consumer needs more money to finish up (house is almost complete when consumer comes to bank). Bank loans money to consumer and takes lien on house. Is this HMDA reportable, if so, as what? Bank is making 15-year permanent loan - loaning $70,000 on house worth $280,000. Examiner first told bank it was not reportable, then said later it was as a home purchase loan and said bank should have provided early Reg. Z disclosures. HMDA Help said it was not reportable.
11/04/2002
Two Questions 1) I'm interested in any discussion and or procedures in place to underwrite consumer loans when applicant does not have a Social Security # however does have a TIN (Tax Identification Number)? 2) Is there anyway to determine if a TIN # is a valid number?
11/04/2002
Is it true that you do not need to provide Truth In Lending for refinances of Investment or 2nd home mortgages.
10/28/2002
There seems to be some confusion regarding the new TIL for High Cost Mtges that go in effect in Oct. Is this new ruling geared towards Primary residents only, or does include investment properties and if so, where can I find the verbage that states just that. I am in the state of Florida.
10/28/2002
What disclosures are required on home improvement loans?