Most Popular Lending Content
Late Charges and Escrow Analysis
02/21/2005
We have a customer who is paying regularly, but late. Can we pay the late charges on the loan from the escrow account there for taxes and insurance?
Contacting Borrower in "Cure" Period
02/21/2005
Can you contact a delinquent borrower during the twenty-day period after you've provided them with a "Notice to Cure Default"? I've been a lender for 24 years and was trained that the lender could not initiate any contact during the cure period, but could respond if the debtor called. We have a difference of opinion at our bank.
What actions should my institution take in order to expand our Assessment Area(s)?
02/21/2005
What actions should my institution take in order to expand our Assessment Area(s)?
Acceptable Margin of Error in TIL Disclosure
02/07/2005
We use margin and index calculations to determine rates for ARMs. The index changes every Tuesday and is to be used on loans closed after cutoff that day. If loan documentation is prepared on Tuesday before cutoff time and has an effective date of Wednesday, the previous index is used. In some instances this creates understated finance charge violations according to APRWIN. What type of exceptions, if any, might be granted by examiners in this instance?
No Fee, Waived Fee and RESPA GFE
02/07/2005
Section 3500.7(a)(2) has been cited as the reason that fees must be disclosed even when the borrower is "not likely to incur them in connection with the settlement." Please see 3500.7(a) where it indicates this only needs to be done when the "borrower is likely to incur" them. How do we reconcile the apparent conflict here?