Jack Holzknecht is the CEO of Compliance Resource, LLC. He has been delivering the word on lending compliance for 39 years. In Jack's 34 years as a trainer over 125,000 bankers (and many examiners) have participated in his live seminars and webinars. Jack's career began in 1976 as a federal bank examiner. He later headed the product and education divisions of a regional consulting company. There he developed loan and deposit form systems and software. He also developed and presented training programs to bankers in 43 states. Jack has been an instructor at compliance schools presented by several state bankers associations. He developed and delivered compliance training for the FDIC and OTS for ten years. He is a Certified Regulatory Compliance Manager and a member of the National Speakers Association. He is also a "BOL Guru."
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If a bank requires an upfront deposit on a mortgage loan application for appraisal and credit report fee costs, is this considered an application fee that must be charged to all applicants even if the application is declined prior to incurring the charges? Reg Z seems contradictory on this issue since appraisal and credit report fees are generally not to be considered finance charges in a real estate transaction.
We are associated with Metro bankers for Title Insurance. The new required disclosure we received has me confused because the first disclosure says: "The lender may not condition an extention of credit, or any subsequent renewal thereof on either: (1) My purchase of an insurance product from the lender or any of it's affiliates;or (2)My agreement not to obtain, or a prohibition on my obtaining, an insurance product from an unaffiliated entity: (3) as long as the coverage provided is acceptable to the lender. I'm unclear because we require title insurance on all real estate loans. The disclosure does not say we require the insurance. Can you tell me if I'm missing either the meaning of the disclosure or is there something else we should be saying.
The question I have is regarding a loan that has several 14 family dwellings on one tract of land. Do we fill out a HMDA form for each dwelling or report the total loan amount on one HMDA form?
Can a bank deny someone credit based soley on the fact that the applicant is a permanent resident of the US but not a citizen?
We do not actively solict the purchase of credit life insurance. However, occasionally a customer will request it. When this happens, we do sell it to them. Do we have to give the Consumer Protection Insurance Disclosure at time of application to all consumer loan applicants on the off chance that we might end up selling them credit life insurance? If not, do we have to give it when a customer asks for credit life insurance? And last but not least am I correct in assuming that if we do not sale insurance to the consumer the initial purchase disclosure is not required?
With falling rates, we're having several customers who want lower rates on their loans. We're agreeing to do this but charging a 1% (of the outstanding loan balance) modification fee. Does this require redisclosure under Reg Z? We are not refinancing, simply lowering the rate and charging the 1% fee. If we were only lowering the rate, I don't find in Reg Z that redisclosure is required, but the 1% fee would that be a finance charge and therefore, trigger new disclosures?
Could someone supply me with the citation in Reg Z which indicates that we must show on our arm tils fed box the different payment streams.For example: 5/l 30 year arm60 months at such and such a payment based on the initial rate300 months at such and such a payment based on the index & margin as of the date of closing.