Regarding the new ECOA Valuation Rule that amends the appraisal provision of ECOA's Regulation B. Would it apply to home builders? I can't find anything in the regulation that it wouldn't.
Is a new truth in-lending required when there is a change in circumstances? (2nd lien)
My bank never prepared early disclosures for a non-owner occupied home equity in the past. About a month ago someone said we should be making those disclosures, so we have started. My question is: Do we really have to send out early disclosures for a loan being backed by a non-owner occupied home?
When the bank imposes 25% penalty rate for 60+ days past due credit card accounts, do they need to send 45-days advance notices to delinquent card holders before imposing penalty rate?
Does a lender need to have a signed copy of the servicing disclosure in the individuals file or can it just be given out with the other documents at origination?
We have a loan to construct a primary residence to two individuals and their trust. The two individuals are also the beneficiaries of the trust that is liable. The land is owned by the trust. Since the loan is to a natural person and a trust should a TIL be disclosed?
If there are odd days in the first period on a mortgage loan (i.e let's say 9 days), we charge the customer the 9 days at closing, it is considered a prepaid finance charge and will be included in the amount financed. When calculating the APR for this loan, would you also include the odd days (9) in the payment stream portion of the calculation?
If you modify an existing consumer loan secured by their primary residence and charge a fee, do you have to disclose with a TIL? The only thing we are doing is lowering the rate and charging a fee.
Is the lender required to send RESPA documents when offering a Modification Loan? The modification has a proposed rate at 4.75%, which is higher than the current rate of 3.75%.
I have an applicant that owns a Duplex that is free and clear and they want to use the equity to purchase a new primary residence. The purpose of the loan is personal. I know that HMDA would apply for the new property however I am not sure about RESPA/Reg Z. When I prepare my Early Disclosures the information that would be disclosed would be a combination. The Origination, Flood, Lenders Title would be on the rental but we disclose Owners Title, Tax Stamps and those figures would only apply to the property being purchased.