Vendor Guru Q&A - Lending

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Latest Lending - Disclosures Topics

Converting Variable Rate HELOC to HELOAN

06/10/2013

What disclosures are required when you convert a variable rate HELOC in default to a HELOAN (fixed rate) and then back to a HELOC (variable rate) after a specific length of time? Can you do this?

Acting As Seller of Repossessed Automobile

06/10/2013

Are additional disclosures required if a lending institution elects to act as the seller of a repossessed automobile?

What APOR Index Date to Determine HPML

06/03/2013

Assuming your interest rate is locked at application and your initial APR is below HPML trigger, if loan fees change causing the closing APR to increase (no change in rate) what APOR index date do you use to determine if you have an HPML? I understood it to be the date the rate is locked or set, but now I'm hearing you also have to verify the closing APR to see if you have a HPML?

Co-Signers Sign Own Set of Disclosures/Loan App?

06/03/2013

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?

How to Handle Tolerance Issue on Real Estate Loan

05/20/2013

On consumer real estate loans, when we have a tolerance issue between prelim disclosures to final documents, we have been providing a revised GFE at closing. Can you tell me if this is an appropriate way to handle this?

Dwelling on 25+ Acres-Considered Commercial Reg Z?

04/15/2013

I know that principal dwelling on 25 acres or more is exempt from RESPA, but do you still consider it as a higher-priced mortgage loan under REG Z or can we treat it like a commercial loan?

What Loan Docs Require An Original Signature?

04/15/2013

What loan documents require an original signature and when is an electronic signature or facsimile sufficient?

Questions for Taking Loan Applications Online

03/25/2013

We are considering taking loan applications online. What are some key things that need to be considered as we go through this process? What questions should be asked?

Why GFE Not Required on Loan Modifications?

03/04/2013

Why do loan modifications not require a good faith estimate or some type of document outlining the specific fees? And why is it not required that loan modifications go through a settlement agent?

TIL Required for Change Terms/Temp Finance?

02/25/2013

We have a construction loan that originated on March 30, 2012 for $400,000. On 11/21/2012, a new request for an additional $17,000 was submitted. We will be changing the terms, adding the additional $17,000. The loan is for temporary financing. Is a Truth-In-Lending required for this?

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Help from the Bureau: The 2013 HOEPA Rule

Even the Bureau agrees: the list and load of new regulations is daunting. And from our current perspective, implementation seems overwhelming. Fortunately, the Bureau is providing some help.

ECOA: Who and What are Creditors

In most regulations, the definition of creditor is pretty clear. The creditor is the entity that makes the loan, who advances the funds, and/or to whom the obligation is initially payable.

Limited English Proficiency

10/13/2019

Do we have to provide translators for loan applicants who do not speak English?

Flood Insurance for 2 Properties

10/13/2019

We have a loan with two properties. One is a flood zone and one not in. The value of the property in a flood zone is $50,000. Can we require flood insurance only on the amount of the property that is in the flood zone or do we have to get flood insurance to cover the entire $250,000.00 loan balance?

Initial Disclosures Before Underwriting?

10/13/2019

Are initial disclosures required to have the borrower(s) signatures prior to going to underwriting for initial review? I understand that the loan estimate and 1003 need signatures but what about the other initial disclosure documents i.e.: toolkit, counseling forms, servicing disclosure, AfBA, FACTA, Privacy, Patriot etc..

Docs to Verify Income or Tax Returns Required?

10/13/2019

We have a married couple wanting to fill out a home loan application. They state that they do not have any copies of their tax returns. Can we use the other documents to verify income or are the tax returns required?

Gross Annual Income

10/06/2019

What income is reported when the income relied upon has been adjusted and is not the applicant’s “gross annual income”?

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