Can an individual loan accommodation for a personal, family or household purpose to an existing borrower with other business loans be considered non-consumer?
We analyze our escrow accounts in December of each year with the payment change effective February. Our taxes are billed based on the owner as of December 31 of the previous year. Taxes are due in October. So this year the estimated taxes due in October would be $260, based on the seller who owned the property as of last year end. The estimated taxes per the county for our borrower are based on the sales price will now be $5,600 based in part on this being our borrower's second home and having no tax exemptions available. We collect a tax escrows at closing and based accrual payments on the $260 we estimated would be owed. My question is, to prevent payment shock to our borrower in the next year, do regulations allow us to change the estimated tax amount to $5,600 AFTER we pay the taxes this year, but BEFORE we perform the escrow analysis in December, or should we only collect taxes based on the $260 for the entire year of 2023 and depend on the borrower to voluntarily deposit extra escrow monies into his escrow account to make up the difference?
We have a consumer construction loan with a fixed rate which we want to extend the maturity with a rate increase. Do we need to re-disclose?
Does an "inactive" NMLS record need to be maintained and updated? The inactive status is intentional since the individual is no longer in a position that requires an an active status. I don't think the record requires maintenance unless the person becomes active again, but I am unable to find any information on that so am looking for an additional opinion.
Why do missing documents create risk for a financial institution?