Under the new QM/ATR rules that take effect on Oct 1, 2022, when does a loan become HPML? Is it still based on the 1.5%-1st lien, 3.5%-2nd lien, or does it now go by the new thresholds in the price-based tiers, for instance, 1st lien is less than $68,908 has a 6.5% threshold between the APR & APOR?
Does flood insurance need to be in effect the day before a loan closes or the day of is sufficient?
We have a HELOC that is going to pay off a tax lien on a dwelling. Should the purpose be reported as "Refinance" or "Other" for HMDA purposes?
What are the potential benefits of automated exception reports?
We receive submitted applications from our website that are considered complete per TRID. Upon receiving the submitted application, we attempt to directly contact the applicants by phone or email regarding the application and items needed to make a loan decision. If we do not receive any contact from the applicant, what are the notification requirements? Should the app be considered incomplete and we send a Notice of Incompleteness and if there is still no response by a certain date, we can close the file? Also, what would the timing requirements be to send the notice and then to be able to close the file?