Do we have to send the credit score disclosure on denial letters for residential real estate applicants?
If a property is in the flood zone and we have a mortgage on it, is the customer required to escrow the flood insurance?
Are appraisal reviews required on all new real estate loans that require an appraisal?
The commercial loan officers at my bank have a general understanding of FIRREA however one among us believes that FIRREA may dictate LTVs on commercial real estate - in particular a vacant commercial lot. Is this true, If so, where can we find an explanation?
I am currently processing a real estate loan in which the collateral is a mobile home park but does not include the mobile homes (7.3 acres land and improvements consisting of the office/common area building only). The flood cert on the entire property came back as not in a flood zone. I have now been told, "Although we are not taking the mobile homes as collateral, since we are aware that they exist on this property, we must do our due diligence and order a flood determination on each building as well as each mobile home". Are you aware of any requirement for banks to order flood certs for property that is not being taken as collateral?
For adverse action notices where the loan requested would not have been secured by consumer real estate, is the credit score exception notice still required?
What rate is used to calculate the interest rate on a loan that is secured by a Certificate of Deposit account? The interest rate on the Certificate of Deposit or the APY on the Certificate of Deposit?
We have a loan for a customer to purchase two lots which he plans to construct his homestead on in the next year. Does this fall under HPML regs? Do we have to provide early disclosures?
I have an application for a refinance of existing debt secured by commercial real estate (a small mobile home park). The twist is, the borrower's primary residence is on the same parcel. The debt we are refinancing is held by another FI and was done for business purposes, as ours will be. Does HMDA apply? I'm inclined to say no.
In charging for credit reports we do not charge unless the loan is closed. My understanding is for consumer loans you must include the fee in the finance charge. Should we also do this with real estate loans since we only charge at closing? We are only charging what we are billed.