Is it a Reg Z violation to not acknowledge a a customer's dispute letter within 30 days of receipt?
If we have a 1-4 dwelling that is being used for a commercial purpose (day care, real estate office, doctor or dentist office etc.) and our lien will be in first position, since the loan is a commercial loan do we still need to send the upfront appraisal notice? If the property is zoned commercial or granted a zoning exception does that matter?
We have a file that started out as a Cash-out Refinance for Home Improvements. So the original purpose would be "home improvement." The appraisal came in much lower than expected. A "change of circumstance" was done to lower the loan amount, which fell short of paying-off the existing mortgage and there would not be enough funds for
home improvements. The borrower withdrew the application. For HMDA reporting, should the loan purpose still be "home improvement" or should the loan purpose now be "refinance"?
Does the rate spread under HMDA Reg C apply to construction loans for residential 1-4 family?
Why do our commercial lenders have to obtain an NMLSR ID number just for HMDA reporting? This is a real burden on financial institutions.
My question is regarding earnest money deposits on a residential mortgage real estate transaction. The file contained a copy of cancelled check from borrower to realtor dated 2/23. The application was after that date and intent of notice to proceed has not yet been obtained. Internal mortgage compliance audit cited violation of 1026.19(e)(2) stating check to realtor should have been dated after ITP. I think they are wrong - since that independent transaction happened outside of the control of the financial institution. I don't believe the EMD date preceding the ITP argument has any merit. Am I wrong? Do you have some advice on how to write some fun (but respectful) rebuttal language?
Our original Loan Estimate shows the loan as construction, but it was in fact a refinance. Is this correctable on a revised Loan Estimate?
I don’t understand how to report the revised HOEPA field. Two of the choices include that the loan is “covered” by HOEPA.
Our institution made the credit decision on a loan purchased from a correspondent, but we did not receive the application directly from the applicant and the note is in the correspondent’s name. How can we report a loan as originated and say the application and first payment relate to the other institution?
I have a commercial loan request from a local labor union. As there will be no personal guarantors, what information can I ask for to ensure the local representatives have authority to borrow money? This union is part of an international union