I know that providing a builder a discounted rate on their personal loan in exchange for the builder referring buyers on new construction is a RESPA violation. However, is it also a violation if the bank provides the builder a deal on the commercial loan that was provided to construct the new homes? That loan is a commercial deal and the discount predates the "hoped" for referrals. There is no agreement, more of a hope the builder provides referrals. It's likely a tightrope but appreciate the insight.
Are we allowed to include the Negative Information Disclosure language in the promissory Note form for all applicable loans? We currently provide a separate one page document with just the Negative Information Disclosure language on it for the customers to sign. I was hoping to eliminate one document by including this in the Note.
What or is there a regulation that requires a paid loan to be processed within a certain period of time?
If the interest rate disclosed in a promissory note is incorrect (it is lower than what is actually being charged), is that a Reg Z problem? What if the TILA disclosure is within tolerance and is considered correct, could this then be an issue with UDAAP?
If we are still delivering disclosures and statements in paper form, do we have to be concerned with E-SIGN or UETA?