For HMDA reporting purposes: An applicant's demographic information is obtained at time of application via an online application process and the
data collected is the information input onto the HMDA LAR. But if the applicant changes the demographic info at consummation (at the title
company) do we change the data on the LAR from the data collected at application to the data collected at consummation?
Do we need to send a Good Faith Estimate on a new HELOC, or would this need a loan estimate and a closing disclosure?
We are a HMDA bank and do not report (open end) HELOCs. Should we still collect Government Monitoring Information for Regulation B purposes when the customer tells us the funds are to be used to purchase or refinance a principal dwelling?
What RESPA violations would a lender be making if they are changing the zero tolerance and 10% tolerance section of the 2010 GFE at closing to
avoid issuing the borrower restitution for the cost to cure.
Is this a bridge loan? The loan is to purchase and renovate a home, only using the home being purchased for collateral. Term 180 days, closed -end line (for improvements). The loan will be paid off with the sale of current home. Does RESPA apply?
If the initial GFE did not list the name, address & phone number of originator can they do a revised one and be okay or will they have to use $0.00 on the HUD-1 comparison and pay the borrowers the difference between $0.00 and the actual cost?
We are making a 3rd mortgage loan to a current customer. It seems ridiculous, but as far as I can tell we need to provide an early TIL & GFE. Is there an exemption somewhere I have missed?
Where do you put the fee on the GFE and HUD for e-filing a mortgage? I read commentary that it should go in the 1100 series but that seems odd if it is a HUD1-A.
How should the buydown fees paid by a 3rd party be shown on the GFE?
I'm receiving conflicting information regarding the ability to use Paid Outside Closing to cure tolerance violations on the GFE/HUD. In short to set the stage, we do not charge closing costs on our real estate loans. Excluding a changed circumstance where a re-disclosure can occur, can POC be utilized in all other instances to cure a tolerance violation? Example: Upgraded appraisal from drive by to full by same appraiser that isn't a changed circumstance, transfer tax error, etc? If so, how would you indicate it on the HUD? In the example of an appraisal, would you show two appraisals being performed on the GFE column of the HUD and then show the one appraisal on the HUD column and a POC appraisal. The intent is to avoid cutting a check to a borrower on a no closing cost loan.