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Latest Lending - HELOC Topics

Update Home Equity Disclosure w/Change Rate Index?

07/29/2018

Do Home Equity Disclosures have to be updated with the change in the index rate or do you just do one annually?

2018 HMDA- Rule on Collecting/Reporting HELOC Data

07/08/2018

We are a credit union and want to make sure that I'm reading this right concerning HELOCs. Under the rule financial institutions originating 100 or more HELOCs will file 2020 HELOC data, but if we originate fewer than 500 in 2018 or 2019 we would not be required to begin collecting and reporting HELOC data until January, 1 2020. As a credit union do we fall under this rule as well?

Reporting Partition HELOC Loans to Credit Bureau

04/01/2018

We are going to offer Partition HELOC loans (a main HELOC and fixed rate partitions). How are these reported to the credit bureau? Just the main HELOC and the fixed rate partitions or just the main HELOC?

TRID Apply to HELOC's? LE's Out Within 3 Days?

01/21/2018

Does TRID apply to HELOC's? Do I need to have LE's out within 3 days of an application?

Reg Z Financed Fees (HELOC Closing Costs)

09/03/2017

If a borrower finances their closing costs on a HELOC, we provide an itemized billing statement. Our software then requires that 100% of those financed fees be paid in full with the first billing on top of any other P&I payment required. Are the financed fees required by the regulations to be paid or is this a software billing issue?

How to Report HELOC on Adverse Action Notice

02/19/2017

On an Adverse Action notice, how should the term of a HELOC be reported? Our HELOCS are 120/180: A 120 month draw period and a 180 month payback period. Should the term of the loan be displayed as 300 months?

Grace Period On Payments For HELOCs

12/04/2016

My institution is launching a new product in the upcoming months, HELOC's. We are currently building the policy and disclosures. It was asked of me if we were required to provide a grace period on payments for the HELOC. I was researching but could not find anything particular.

HELOC and margin

08/07/2016

Currently, our HELOC products feature a rate determined by an index plus a margin (we utilize Prime). However, we'd like to lower the margin for the time being but not actually get rid of it. Basically, calculate the rate with a lower index for now but keep the existing margin in place for the future. This would seem to be a change in the interest of the borrower as it will allow a lower rate.

TIL Disclosures

07/31/2016

Is a Truth-in-Lending disclosure for HELOC the same as the Initial Disclosure?

HMDA & ECOA: Rejected closed end counteroffer

05/30/2016

We have an application that started as an $18,000 home equity line of credit (HELOC) for home improvements. The bank counteroffered the applicant a closed end mortgage in the amount of $8,671 and they accepted that offer and their government monitoring information was then collected and disclosures were sent. Days later the applicants called back and stated after further consideration they were not comfortable with doing the closed end mortgage, which raises a couple questions: 1 – do we go back to the original request of a HELOC and deny the HELOC application for excessive LTV listing our counteroffer; or 2 – do we report the accepted closed end mortgage counteroffer as home improvements on our HMDA LAR as a withdrawn request?

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CFPB Mortgage Servicing Tools

The CFPB updated its Small Entity Compliance Guide (Version 3.1) for the 2016 Mortgage Servicing Final Rule on March 29, 2018, to incorporate the changes made by the March 8, 2018 final amendments.

Help from the Bureau: The 2013 HOEPA Rule

Even the Bureau agrees: the list and load of new regulations is daunting. And from our current perspective, implementation seems overwhelming. Fortunately, the Bureau is providing some help.

Timing of rate change notices

08/12/2018

Our vendor says that we have to send a rate change notice 210 days before the first payment at the adjusted level. This can't be right. We have no idea what the adjusted rate will be that far before the adjustment date.

Procedures for Force Placing Auto Insurance

08/12/2018

What are the procedures for force placing auto insurance on a customer, who's auto policy has lapsed? I have found procedures for hazard and flood but wondering if there are different procedures for vehicles.

Home Used for Business Line of Credit-HMDA Report?

08/12/2018

Is the following scenario HMDA reportable? The borrower owns his primary residence free and clear. He is going to use this home for a business line of credit. The purpose of the business line of credit will be for him to purchase homes, repair or remodel and resell. (He is flipping them.) We will be advancing funds and depositing to his checking account and we will have no interest in the homes that he flips.

New Business Loan App for the New Borrower?

08/12/2018

I have an entity assuming the debt of another to purchase a residential property. Since the loan will be secured by a first lien on a residential dwelling, will I need a new business loan application for the new borrower? Our original business loan application specifies the original borrower.

When can we use a scan of an ID?

08/12/2018

We are offering loans via a mobile app. Can we accept scans of IDs as that is a good way to help verify we are engaged with our customer, by having them send us a picture of their ID using a smartphone.

Latest Lending - HELOC Topics

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