Most Popular Lending Content
If a Director provides RESPA settlement services, do we need to provide the Affiliated Business Arrangement Disclosure to every mortgage applicant?
11/18/2002
We were recently advised at the bank, where I am employed, that we must use the Affiliated Business Disclosure on every residential mortgage that we do. We are located in a small town where the majority of the customers we have choose to use the local attorney. I specify choose. Upon an examine we were told that it looked like we were making the customers use this particular attorney and that we had to give the Affiliated Disclosure on each an every mortgage because one of the attorneys is a board of director for our Holding company. Now, since we are doing this and a customer has chosen another attorney, it looks like we are soliciting for the local attorney. Do we indeed have to give this to every mortgage customer?
HOEPA & Mobile Home Loans
11/18/2002
Does HOEPA apply to mobile home loans not secured by real estate?
Forms For Loan Officers
11/18/2002
Do you have a form you can e-mail me that I could give my loan officers to report back and know when and what to follow up on?
Prior Appraisals & RESPA
11/18/2002
We have a discussion going on regarding RESPA as to having to disclose an appraisal fee as POC when lenders use a prior appraisal on file or one the customer may have obtained year(s) ago or when lenders do an in-house appraisal/evaluation. There is no cost to the customer. Lenders state they are not requiring an appraisal but use the appraised value in their credit analysis. The key word here is REQUIRE. An FDIC Examiner stated that if you use a prior appraisal or do an in-house evaluation(we do not charge) that you should show a cost as POC. His reasoning is there was a cost to the customer at one time. The Examiner referred me to FIL-45-2000, Q and A #7,#4, #8. One of our lenders attended a seminar on RESPA and ask this question. The instructor stated he had never heard of such a thing.
Flood Insurance Cheat Sheet
11/13/2002