I have a lender telling me that the borrower was considered to have shopped for services because the provider listed on the Settlement Service Provider List (SSPL) has 3 office locations and the borrower went through a different office location than that disclosed on the SSPL. The lender believes going to a different office address is considered "shopping." I don't agree, but would like clarification on this.
Our bank collects a fee for future mortgage releases. Even though at closing the fee goes to us, eventually it is paid to the county clerk when we release the mortgage.
For the purpose of the Loan Estimate and the Closing Disclosure is this fee considered paid to the Lender or to the County Clerk? Either way it would still be a 10% Tolerance category correct? If it is paid to the lender would that mean it needs to be included in the finance charge that affects the APR for calculating HOEPA?
Prior to Integrated Disclosures, a credit sale (selling and financing an OREO property) required us to disclose the Total Sale Price on an Estimated and Final TIL (12 CFR 1026.18(j)). Is there a similar requirement on the new Loan Estimate and/or Closing Disclosure or has this gone by the wayside?
Under the new TRID rule, where would a Condo Questionnaire Fee be disclosed on the Loan Estimate? The questionnaire is required for the transaction but some condos may or may not charge such fee.
With the new TRID regulations from October 3, now placing lot loans under Regulation Z, in the event of refinancing a lot loan, does the right of rescission apply?
In order to expedite closing, can the Loan Estimate be issued on the same date as the CLoD?
We have a purchase contract that lists the seller paying both pest and warranty, are these disclosable?
We had a customer apply for a loan secured by their primary dwelling. The rate was locked at 3.75%. The revised GFE was issued stating the rate at 3.875%. Correct rate is 3.75%. Is this considered a changed circumstance?
Is the disclosure of prepaid property taxes required on both the LE and CloD only if a creditor requires that this be prepaid?
I am doing a 6 month interest only loan to a customer to make home improvements. I am not escrowing for taxes or insurance for this loan. Do I still need to disclose the "Estimated Taxes, Insurance, and Assessments" on page 1 of the new Loan Estimate?