Most Popular Lending Content
Extensions on missed construction loans
12/17/2023
Are there alternatives to extensions are others using when dealing with construction-to-perm loans that are not finished my maturity? We are considering the possibility of advancing any remaining proceeds available on the loan to a checking account, which would have a hold to prevent use outside of the original agreement, and starting P&I repayment rather than extending the loan. We would continue to draw those funds to complete construction, just from the checking account rather than the loan itself. Curious if there are any drawbacks or compliance issues with this method.
Exceptions to HOEPA and HPMLs
12/17/2023
Are short term loans (loans that will not be satisfied and replaced with permanent financing; paid out in full instead) subject to HOEPA and HPML? I see that temporary loans and bridge loans -12 months or less (loans that will be satisfied and replaced with permanent financing) are not subject to HPML. I believe temporary and short term loans are subject to HOEPA though.
Examples of Commercial Loan Software
12/17/2023
Aside from LOS, what are some common types of commercial loan software?
Military Lending Rules
12/17/2023
Hasn’t military lending been quiet this year?
Excluding Filing Fees from Finance Charges
12/10/2023
A UCC filing fee paid to a government entity to perfect a security interest in a consumer product must be listed in the Fed Box to avoid being a finance charge and included in the APR. Our filing fee is paid to a non-government third party vendor. Because of this third party involvement, our compliance department feels the fee should not be listed in the Fed Box. If all or a portion of filing fee we charge to the borrower will be paid to the government entity I feel that portion should be noted excluded from the finance charge and APR. Do you agree?