01/17/2021
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?
09/20/2020
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.
06/21/2020
Is a PMI Disclosure Required for 2nd Homes?
04/12/2020
Is the Notice of Right to Receive Appraisal Copies required on 2nd liens?
03/29/2020
When a consumer comes in and rewrites a loan, with no new money advanced, are you required do to a new application or Reg B form?
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..
02/03/2019
On a consumer real estate ARM loan, the loan just adjusted. The officer is requesting to modify the loan and change the index, margin, and adjustment period. The request is primarily due to competitive reasons. Can we change the index, margin, and adjustment period without having to do disclosures?
01/06/2019
HELOC's primary residence upon maturity and the applicant wants to renew the loan for another term. No new funds same type. What disclosures are required?
09/16/2018
For HELOC early disclosures (ex. appraisal notice, consumer credit score disclosure, acknowledgment of receipt of counselor list, home equity application disclosure,) is the borrower required to sign these forms to acknowledge receipt, or can we have copies and a letter listing them out as proof in the file that they were delivered?
07/29/2018
Do Home Equity Disclosures have to be updated with the change in the index rate or do you just do one annually?
