06/03/2018
If we increase an overdraft line of credit (unsecured) limit, what documentation do we need? Does the customer need to sign anything? Do we have to do a whole new loan or just document it in the file?
04/22/2018
I have a borrower who wants to pay off credit card debt with a consumer loan from our institution. The collateral in this case would be two vehicles and I would like to reference an existing mortgage that is on a rental property (owned by my borrower's father.) The borrower is not the owner of the RE 1-4 family rental property. What RE disclosures do you see need to apply?
10/29/2017
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?
01/29/2017
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.
11/20/2016
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?
11/06/2016
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?
10/02/2016
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?
06/12/2016
Do we have to provide the appraisal disclosure for loans denied within 3 days?
05/29/2016
Are the seller-paid real estate agent commissions required to be disclosed on the Closing Disclosure?
01/24/2016
Is the Kentucky Insurance Disclosure required on all loans, consumer and commercial, or is it just a consumer (Reg Z applicable)
requirement?