We added a co-borrower to our loan and sent a revised Loan Estimate to this co-borrower, but not initial disclosures. Are we out of compliance? Is there any way to cure this before loan closes if it is a problem?
On Home Equity Line of Credit statements, is it required or acceptable to include the FDIC and Equal Housing Lender logos for notices and statements?
I am looking for some clarification on disclosing the finance charges section which states the components of the finance charge shall be individually itemized and identified to show the amount(s). Start up fees - charges are financed as part of the plan, including charges that are paid out of the first advance, charges must be disclosed.
My question is, we have a HELOC that financed all fees into the loan. Our operations department was told to list them individually. However, they combined the Recording and E-Recording fee as a single total, with the description of Recording Fees. Then the Title Insurance fee and Title Services fee were shown as a combined total with the description, Title Insurance Fee. Would this suffice or should they truly be separated out? My recommendation was to list them all out, to mitigate confusion but our operations team is unsure if we can add the additional fee modifiers to our banking system.
Under TRID rules the bank must send a copy of the appraisal three days prior to closing the mortgage loan. If the appraisal is sent electronically but the customer has not opened the email, has the bank met the regulatory requirements?
For the HUD-SCRA notice disclosure sent to past-due mortgage borrowers is there a specific minimum font size requirement?
As an independent mortgage banker disclosing an Adjustable Rate Mortgage, is it necessary to provide the consumer an ARM disclosure or are we covered by disclosing the Loan Estimate and Closing Disclosure which provide ARM details?
A lender entered data for a completed mortgage application but failed to send out any the disclosures. Instead, they asked that the file be withdrawn and a new application was entered into the system and that file has been approved to close. This second entry will result in a new mortgage loan. What do we do with the original file?
All of our TRID loans are on a variable rate that changes monthly. I thought the required rate cap was an increase or decrease of 2% each time it changes. Now I cannot find any documentation regarding this issue. I know we have to disclose the ceiling but is the adjustment under our discretion?
I have recently learned about a rather unique construction perm product and
have a question about it in regard to the new upcoming TRID rules. Here's
how the product functions now. The loan is a one-time close, 30-year term,
fully amortizing from the beginning. Only one LE/CD is issued. The rate is
fixed at opening and does not change at all during the term. There is no
interest-only period. At closing, the funds are put into an escrow/reserve
account and disbursed to the borrower periodically over the construction
period. At this time they do not charge any inspection fees but are
considering changing their process to have the inspections conducted by a
third party and charging for three inspections.
If these fees are disclosed to be collected at consummation, what recourse is
there if an event occurs that requires an additional inspection? Does the
bank simply have to absorb that cost since this is a zero tolerance cost and
the CD has already been issued and compared to the LE?
If these fees are to be collected after consummation, disclosed on a separate
addendum, and this event requiring the additional inspection occurs, can the
bank simply collect the additional fee without violating the zero tolerance?
Our mortgage department is putting together a script for a generic radio ad promoting their department and our offering of home loans. I know the obvious requirement of FDIC and EHL being mentioned. However, I'm unable to find concrete support as to whether our bank's NMLS ID must also be included. I saw a comment in the forum stating that banks aren't required to include it but can't find regulatory guidance to support that. Can you offer me some wisdom or direct me to a resource? I'm in Texas, by the way. I've also searched for state specifications and came up empty.