We have an interim construction loan that the real estate is in flood zone AE. Our Deed of Trust lists the real estate and the construction materials including drapes. All of the construction materials listed are covered under the buildings flood insurance, however the drapes are not. The plans and specs for the construction does not list drapes. Do we have to require contents coverage just to cover the drapes since it is listed in the Deed of Trust?
I need to know in this scenario if a CTR is required for the husband? The wife and husband come into the bank. The wife conducts a deposit to her personal (individual) account of $8,000 in cash. Then she conducts a deposit into the joint account (with her and husband) for $2,600. In my mind a CTR only needs completed on the wife because the wife is benefiting and conducted the $10,600 deposit. The husband did not conduct either transaction and is only benefiting from $2,600. Is my thinking correct? If required, please explain why a CTR is needed for the husband. Also, if a CTR is needed for the husband, I would like for you to consider this same scenario but without the husband present for the $8,000 deposit to the wife's account. When he enters the bank to make a $2,600 deposit to the joint account and we tell him we need to complete a CTR, wouldn't we be breaching customer information to tell him it is because his wife made a large cash deposit to her personal account early in the day?
I have a loan secured by a dwelling and a savings account. According to the HMDA commentary, I include the savings account when computing the CLTV. Okay, that's clear enough. My question is, do I include the savings account in reporting property value? Do I only include real property?
If you have changes to a loan product or loan amount, etc. one day prior to the initial closing disclosure being issued, can you use the initial CD to disclose the changes or do you have to reissue the loan estimate and restart the clock, or is there another solution?
My compliance officer says we have an affiliated business arrangement with a title insurance company that is 20% owned by our holding company. I thought the rules kicked in with 25% ownership. Who’s right?