If a customer is disputing a transfer of funds between accounts on which she is a signer, whether it was done via
online web, mobile phone, ATM, at a branch or over the phone with a banker, does this fall under the Regulation
Is a construction only loan to a consumer covered by HMDA when there will be a separate loan for the long term financing??
Does ROR apply to an Agriculture 1st Mortgage land purchase loan when taking a 2nd mortgage equity lien on the borrower's residence? Borrowers are not full-time farmers and the loan is made to them individually (not a corporation or "business").
I have a purchase money mortgage with a non-occupant co-signer. Can both parties sign one set of disclosures and one loan application or do we need them to each sign their own set?
In reference to the SCRA, I understand it applies to obligations obtained prior to a military member entering active duty. If a member was on active duty when they obtained a loan--be it Guard, Reserve or Regular component--separated from the service, then enlisted again or was recalled to active duty after a break in service, would that member qualify for SCRA relief if they were to apply subsequent to the reenlistment or recall?
For home improvement loans in Texas, does Reg Z apply? Is there a list of requirements somewhere?
We qualify loan applicants based on gross income. Our credit officer says that tax free income from SSI or VA Disability is the gross income and shouldn't be grossed up. I say the income is net and should be. Who's right? If we don't gross tax SSI up, are we discriminating?
We have a customer who took a 3/3 ARM four years ago. It adjusted at the three year mark as normal, but then adjusted one year later (last month). When the customer contacted us, we realized that it had been mis-entered in our system as a 3/1. The customer has benefited from a lower rate at this point (first new payment is currently due), but we are not sure of the implications from correcting this. My thoughts are to do one of three things: 1) Allow this payment to be made at the lower rate, but change the product back to the 3/3 at the current (higher) rate for the remainder of the term. 2) Offer to keep the lower rate and do a modification to a 3/1 if the customer accepts. 3) Change the product back to the 3/3, but keep the lower rate for the remainder of the period (2 years) Any thoughts from a compliance or legal standpoint?
Settlement/closing fees are calculated in the APR. If the borrower chooses his own settlement company, which is not on our list, and they have a flat rate closing fee that kicks the APR into HPML status, and we don't do HPML, can we require the borrower to use another settlement company?
Do we need to provide insurance disclosures to a customer who purchased credit life A/H insurance on a loan with a business related purpose?