Most Popular Lending Content
Dwelling as secondary collateral
02/17/2019
The primary collateral for a loan is business assets, although a dwelling was also taken as collateral. Is this loan not reported for HMDA?
APR Paid by Lender-APR Fee from Borrower?
02/17/2019
If an APR fee is paid at closing by the lender should it still count as a APR fee the borrower pays?
Updated Index for Discounted Rate on ARM Product
02/17/2019
We offer a discounted rate with some of our ARM products. We use the index at the time the rate was set to calculate the fully indexed rate throughout the entire loan and that is what is disclosed on the LE and CD. Under what circumstance would we locate an updated index from a the date of closing or within 45 days of closing and disclose a blended APR. Would this be a 2 time construction closing? We disclose based on once the rate/index is locked that is the rate/index we use when we close. Unless of course the loan is re-locked for any reason.
Notice to Commercial Real Estate Purchasers"
02/17/2019
What, if any, is the regulatory cite requiring the lender to provide the borrower a "Notice to Commercial Real Estate Purchasers?" It is related to CERCLA.
CFPB Update On Construction Loans (Perm Financing)
02/17/2019
We are being told that the CFPB has given an update on construction loans at the time of perm financing. We are understanding it to read that if you do the modification into perm financing (no new loan) it is not HMDA reportable. Does this mean a construction loan would never to reported if this is the case?
