When there is a mortgage on a non-residential condo unit and the property requires flood insurance which is provided by the condo association, what is the best practice for the mortgagee on the unit so as to be notified if a lapse in coverage occurs? Our borrower has the inside of the unit covered for flood, but the condo association is not otherwise providing us with information on the common areas its policy covers.
Our original Loan Estimate shows the loan as construction but it was in fact a refinance. Is this correctable on a revised Loan Estimate?
We mailed the borrower’s Loan Estimate and they emailed us that it was received and they want to proceed with the loan. Can we act on this emailed notice?
How do you calculate flood insurance on a duplex where the borrower is purchasing both and they will live in one as their primary residence and the other side will be a rental? There will be two separate purchase loans; one for the primary residence and one for the rental. Does it make a difference if it is titled differently vs titled the same?
We are going to finance the purchase of a mobile home. Would this be HMDA reportable?
Is there a difference between a manufactured home, and a "pre-cut, tilt-wall" or "panel" home?
What approach do other lenders take when a property is not in a mandatory purchase flood zone, but "maps-in" during the origination of the loan? In some institutions, we've had a process to verify the flood zone prior to close, but others have allowed loans to close and immediately put the loan into the 45-day flood letter cycle?
On an HPML, can the customer cancel their escrow account if the loan has been on the books for more than 5 years?
I have a question related to long backdating (or just backdating) for force placed insurance. I am not finding a lot of information regarding backdating polices other than the standard 45 days that is required when placing a policy that has lapsed or expired.
Does anyone know if there are current lawsuits concerning backdating a policy to an 'effective date' and charging the customer for that time even if nothing happened to their dwelling? For example, when we charge the customer on the 45th day of a new
policy, but it is back dated to when their policy expired or lapsed, is this seen as a UDAAP issue with consumers? In essence we are charging them for a policy when they did not have a claim, so I am unsure what recommendations I should make regarding backdating polices. And, there are no kickbacks, this is simply a backdating question and premiums for servicing. I hope this makes sense! I am having difficulty finding any litigation and/or trends regarding this. Any feedback is welcomed. I am familiar with the process of 1024.37 however am looking a little deeper into the effective dates of polices placed, hazard or flood. Also cannot find much on Fannie Mae or Freddi Mac.
We are on a loan audit at a client's bank. Loans with collateral located in a flood zone are escrowed to pay the premiums. This bank allowed a policy to expire and didn't pay the premium until 3 days after the expiration of the policy. I know I read somewhere in the new rules within the last 2 years that bank's have the responsibility of paying flood premiums timely, before the expiration of the policy. Did I dream this or is it part of the new rules? If so, where can I find it.