11/17/2003
Can we use variable rates for consumer residential construction loans? We've been told by consultants that consumer construction loans HAVE to be fixed rate.
11/17/2003
I am trying to verify for an auditor that we are calculating the APR and payment stream correctly on the final TIL. The loan I am working with is a 3/1 ARM mortgage loan. I disclosed the first 36 payments based on the original contract rate, the remaining payments were based on the current index plus the margin for the balance of the term of the loan. The new rate was actually less than the contract rate since the index is so low at this time. I am confident this is correct and have verified it with our doc prep company - but no one has been able to show me this in writing. I have been reading Reg Z, the Commentary, and anything else I can find - but so far I can only find info on the initial disclosure and not the final disclosure. Where can I find and print the correct procedure for calculating the APR and payment stream that is to be disclosed on the final TIL ???
11/01/2003
The agencies are in the process of publishing new examination procedures for the new components of anti-money laundering programs generated by the USA PATRIOT Act.
09/29/2003
For the upfront lending disclosures (e.g., Servicing Transfer Disclosure, ARM disclosures, etc.) for which the Bank is required to keep a customersigned acknowledgement of receipt, can the Bank substitute a "Disclosure Acknowledgement" form which the customer signs acknowledging receipt of all the disclosures? Or do the regulations require that the disclosures be individually signed?
08/18/2003
This has to do with ARM (LIBOR) interest-only loans. On our final TIL disclosure schedule of payments it shows that the amount of payments have decreased. This is due to historical low interest rates. Obviously, the calculation or formula is not shown on the TIL. However, in order for our IT department to program our system to calculate this type of loan product, I need a basis for the calculations. My question to you: is there a particular Web site that shows exactly how to calculate the ARMS interest only based on LIBOR index (decrease payments)? I've spent the past few days surfing various Web sites (including OTS, OCC, and Treasury) regarding this question to no avail.
08/04/2003
Our bank is going to start offering online loan applications for customers to print, fill out and send in for home mortgages. Do we have to give any disclosures out on the Web site to customers printing up a loan application? We will also be taking applications for new accounts online. To stay in compliance with the CIP regulation, will they have to come into the bank for the account to be opened? Do we have to have the disclosures online or can they be given to the customer when the customer comes into the branch?
02/02/2003
What type(s) of variable rate R/E loan (s) exempt from ARM disclosures?
01/06/2003
What is the correct way to complete the Truth in Lending disclosure on the payment schedule portion, when you have a one year adjustable rate mortgage? Also, do you know where I can get a copy of the 10 year index? Isn't this a requirement for all ARM loans?
08/01/2002
HUD has published a proposal to make significant changes to the Good Faith Estimate that lenders issue within three days of taking an application. HUD calls this a "simplification" of the GFE.
03/01/2002