When the bank is refinancing a loan and the loan is subject to HOEPA, the customer has to go to consuling. After the LE is given, the customer comes back and says he cannot afford the $100.00 consuling fee. Can that fee be added as a fee charge or should it be added to the amount requested? If added to the amount requested, does this trigger a right of rescission?
We deal mostly with foreign national borrowers. We understand RESPA and TILA do not apply, however we disclose to these
borrowers. In the event we stop disclosing, what documents do we still need to provide the borrowers with --application, ARM
disclosure, LE and CD? Please clarify.
Are state-specific disclosures (such as home equity or ARM, etc.) specific to the borrower's residence state or the state of the originating bank is? If a borrower crosses a state line to use a branch nearer their home or a borrower is buying a vacation home in another state and goes to a bank in that state, which state applies to the disclosures?
What is my best source to locate the exact disclosures and agreements that lending customers must be given and or signed to be in compliance?
We are third-party appraisers. We saw something that we have never seen before. We have a bank that is charging a customer $3000 for a commercial loan appraisal, while we were charging the bank $1800. At the very least we thought there should be some sort of disclosure that there is fee income to the bank in that pricing structure.
This is a commercial loan, not a consumer loan. We are aware that the disclosures do not apply for many items, But should not fee income to the bank, versus a actual pass-through fee be shown?
Do we have to provide the appraisal disclosure for loans denied within 3 days?
Are the seller-paid real estate agent commissions required to be disclosed on the Closing Disclosure?
Is the Kentucky Insurance Disclosure required on all loans, consumer and commercial, or is it just a consumer (Reg Z applicable)
When making a RE loan on unimproved land is a FACT disclosure required?
I have a borrower who is using a CD as security for a loan to purchase a vacation home. What if any disclosures are needed?