09/15/2024
Can I advertise "FREE APPRAISAL" on a mortgage postcard, but indicate in small print (client must pay the appraisal upfront, reimbursement will apply once the loan has closed), to that statement OR "FREE CREDIT REPORT," one or the other?
05/05/2024
Overdrafts may be one issue, but what about a late fee waiver on a loan for bank director - would this be a violation of Reg. O?
09/10/2023
If we are charging a modification or change in terms fee, and call it an administrative fee on a consumer dwelling secured loan, and the LOS prints and customer signs the document, I understand that this is allowed because the modification is not considered a refinancing under Reg Z. However, I am being asked how charging a fee payable to the bank does not affect the APR and require new disclosures?
03/26/2023
Is it required to have a separate "Agreement to Provide Insurance" form signed for non-real estate secured loans? We are in Tennessee and currently have a section in the Security Agreement that prints with the Note which states the borrower agrees to keep the property insured and if they fail to provide insurance, then the bank may place insurance on the property (Creditor-Placed Insurance Notice) and pass that cost to the borrower.
12/25/2022
We have a builder in one of our markets who is the seller on one of our transactions. He wants to pay to buydown for the borrowers interest rate. This would cause us to go over the points and fees threshold. My question is, would a seller paid amount to take the rate down be exempt from the points and fees calculation?
05/01/2022
If we charge a $25 return check fee for dishonored loan payments, is this charged to the principal balance or like a late fee that doesn't effect the balance? This charge is disclosed to the borrower.
02/27/2022
My company is a non-depository mortgage company. We would like to partner with banks/credit unions that don't offer mortgages. Once upon a time I had seen an "app taker program" wherein a financial institution could pay another financial institution for work done on an application. For example - the bank that doesn't offer mortgages would help the client complete an online application then provide all income/asset documents. For this my company would pay the bank 0.5% fee, shown on the CD, for their services provided. Can you please direct me to the section of the regs that would discuss this and/or provide information you might be familiar with related to this topic?
04/11/2021
What are or where can I find the allowable fees for a VA mortgage?
03/07/2021
intent to proceed prohibits charging fees other than for credit report before the Loan Estimate is provided and the applicant's intent to proceed has been confirmed and documented. If due to a technical issue which we discovered post closing the Loan Estimate was never sent to the borrower, is the lender obligated to refund all closing fees based on the Intent to proceed rule?
05/10/2020
Can a lender charge a customer for the cost of a soft credit pull prior to an application for example for a prequal or preapproval? I have heard that
there are no federal prohibitions on doing this, but I would like to have more than one perspective please.