06/02/2008
If an ARM loan is at a premium rate do you have to disclose the TIL at a second payment stream at the full index, which is lower than the initial premium rate?
02/04/2008
When we disclose an early TIL for an adjustable rate mortgage, we use the most recent available corresponding Treasury index figure when calculating the second payment stream for the APR. If the loan closes weeks later, should we then use the most recent index figure even if it differs from the early TIL?
11/12/2007
If we have a loan with a 15 year term and a rate that adjusts every 24 months and another loan with a 10 year term that adjusts every 60 months, can we give the 20 year/24 month ARM disclosure and the 20 year/60 month ARM disclosure, respectively, or must the disclosures be an exact match to the loan terms, i.e. 15 year/24 month and 10 year/60 month, respectively?
11/05/2007
When completing the HOEPA worksheet, is the scheduled payment field for the principal and interest only or should we include taxes and insurance? Also, if this loan is a 3/1 ARM, when calculating the largest payment should we use the ceiling that is on the Note taking into consideration any principal payment made by the borrower in the first 3 years or use the original loan amount in the calculation?
09/17/2007
What are the required disclosures for declined loans and what are we required to keep in the file for audit purposes on declined loans?
04/30/2007
During an internal audit, we recently discovered that we have a few ARM loans that were set up on our system incorrectly, the payment was not set to change when the rate changed. As a result, we have basically extended the amortization on these loans by not increasing the payment along with the corresponding rate increase. How would you suggest we rectify this error? What are all of the compliance ramifications such as TIL, restitution, etc.? We have an exam coming up and would like to show examiners that we have identified this error and corrected it.
02/12/2007
I'm working on a matrix for quoting APRs and I need to know what the guidelines are for quoting APRs on ARMs. I've checked [Bank name withheld] website and for a 5.75% rate their APR is 7.026% on $145M, 1pt, 30 yr, $2000 prepaids, 5/1/5ARM. Are they just using what the max could be at first adjustment? I can't see where the Reg discusses APRs on adjustable mortgages.
11/20/2006
When disclosing a payment schedule on the TIL for an option ARM, is there a tolerance for variation due to rounding issues permitted by Reg Z in the calculation of the payments that appear in the payments stream?
11/13/2006
When disclosing a payment schedule on the TIL for an option arm, is there a tolerance for variation due to rounding issues permitted by Reg Z in the calculation of the payments that appear in the payments stream?
07/10/2006
I am confused by the Truth in Lending rules and FTC Guidance (How to Advertise Consumer Credit) on how to advertise the following product: 10/1 LIBOR ARM. Repayments are "interest only" for 10 years with a fixed rate, then for the remaining 20 years (30-year loan), the rate becomes variable and the loan is amortized for principal and interest payments. At a minimum, our line of business wants to advertise the amount of the monthly payment. Is this a Graduated Payment feature loan, or a Discounted Variable Rate Plan or something else? Any real-life examples are appreciated.