03/21/2021
If I used an estimated value on a loan estimate for a construction loan where the customer already owns the land and no appraisal or valuation has been completed, will I use that same estimated value on the closing disclosure or can it be updated to the appraised value?
01/17/2021
If the lender provides the fire and hazard insurance on a mortgage loan, is
this a zero tolerance for the loan estimate? While one can do a pretty good
job using MLS / Internet to come up with an insurance value, but this amount
could change when reviewing, say an insurance review that would be obtained
prior to the closing disclosure. Say MLS cited 800 sq ft, but the insurance
review cited 1200, or even if a for sale by owner, (FSBO), with limited
"online" information, the insurance review comes back noting a custom
kitchen, flooring, bath etc. when this was not known up front.
10/04/2020
We had a mortgage loan, a refinance, subject to TRID and we charged a Title Insurance fee upfront on the Loan Estimate of $765 and it was actually a Title Search for $50. The Closing Disclosure was not changed either. How do I complete a revised CD after consummation; Do I just refund the $715 or do I need to complete a revised CD?
08/26/2020
We have a loan that we are working on that is a purchase of a second home. The borrowers are son and daughter in law and mom. Son and daughter in law live in Michigan, mom lives in Florida.
* How do we get the closing papers signed and what should they be dated?
* Do we send two closing packages, one to each and then combine them, or send one closing package and have the son and daughter in law forward to mom?
* Can they date the documents before the closing?
04/26/2020
Should a cured fee (Underwriting Fee) be included in the finance charge calculation?
The fee was not originally disclosed on the LE. Therefore, it was not included in the APR. The item was added to the CD and cured. Since it was cured it was not included in the APR/finance charges.
03/29/2020
After watching an escrow webinar my bank decided to no longer add the 3% to the premium amount on the closing disclosure. Since the webinar, I have forgotten and did not properly document why. Can you please confirm or advise me on the initial escrow statement, per regulation, if we can add this? I recall it was created from the CPI Index. I understood this could be added at the annual escrow analysis, but NOT on the closing disclosure or Initial Escrow Statement/Disclosure. Is that right, or can we add the CPI index at the time of creating the escrow account?
03/29/2020
After watching an escrow webinar my bank decided to no longer add the 3% to the premium amount on the closing disclosure. Since the webinar, I have forgotten and did not properly document why. Can you please confirm or advise me on the initial escrow statement, per regulation, if we can add this? I recall it was created from the CPI Index. I understood this could be added at the annual escrow analysis, but NOT on the closing disclosure or Initial Escrow Statement/Disclosure. Is that right, or can we add the CPI index at the time of creating the escrow account?
03/15/2020
I'm looking for clarity concerning Reg Z and documenting a borrowers payment of costs on the Closing Disclosure that are paid outside of closing. Specifically, fees for optional services like a Whole Home Inspection, Radon, etc. that a lender does not require. I thought there were separate rules for optional services?
Reg (i) Charges that are not paid from closing funds but that would otherwise be disclosed in the table described in paragraph (k) of this section, should be marked with the phrase “Paid Outside of Closing” or the acronym “P.O.C.” and include a statement of the party making the payment.
03/08/2020
We gave a lender credit of $2,500 on the LE for a "no cost" loan. On the CD, we showed all fees paid by the lender, with total specific lender credits of $2,600. However, our origination fee of $500 shown on the LE was waived and removed on the CD, offsetting an increase in a title service fee
of $600. In short, we are paying more in credits than originally disclosed, but have removed a waived fee. Is this acceptable?
02/09/2020
Can a lender accept verbal telephone confirmation from an applicant of receipt of the 3-day closing disclosure?
