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Latest Lending - HELOC Topics

HELOC for Borrower w/PMI Insurance on Mortgage?

09/08/2019

Can a Home Equity Line of Credit be done for a borrower who has PMI insurance on their first mortgage?

Including Taxes/Insurance as Expenses for HELOC

07/28/2019

We know that HELOCs are exempt from 12 CFR 1026.43. Our borrower is applying for a HELOC. He has four residential properties which he owns and is paying the taxes and insurance on these. None of these are his primary residence nor are they investment properties. The taxes and insurance are not on the borrower’s filed tax return . Do we need to include the taxes and insurance for these other non-primary residence real estate properties as expenses when qualifying the borrower for a HELOC?

Rate Change Notice if Prime Increases? HELOC/ARM

05/12/2019

Our HELOCs are tied to prime. We disclose that. If prime increases do we need to send rate change notices?

Info on Notice of Right to Cancel for New HELOC

03/03/2019

The previous Commentary to Reg Z at 1026.5b contained the following statement regarding a matured HELOC: "...A new plan results; however, if the plan is renewed (with or without changes to the terms) after the scheduled expiration. The new plan is subject to all open-end credit rules, including sections 226.5b, 226.6 and 226.15." I have not found any comparable interpretations by the CFPB since the CFPB took over responsibility for Regulation Z. I'm looking for any information that will support the need, or lack thereof, to require a Notice of Right to Cancel when a new HELOC note is executed after the existing HELOC has matured.

First Reserve/LOC & HELOC’s as estatement?

03/03/2019

Is there any reason why we are not allowed to have First Reserve/LOC statements and HELOC’s to be estatement?

Disclosures for HELOC-Upon Maturity Renewal

01/06/2019

HELOC's primary residence upon maturity and the applicant wants to renew the loan for another term. No new funds same type. What disclosures are required?

HELOC Increase-Rewrite As A New Loan?

12/23/2018

If a customer has an existing Home Equity Line of Credit and then approaches to increase the HELOC by an additional amount of money, can a Change in Terms Credit Agreement and Disclosure be used for that or do we have to rewrite the loan as a new loan request? Obviously, if we are able to use the Change in Terms agreement, a Modification of Mortgage would need to be prepared and filed of record. What about Rescission on the new money? Do we have to give them an actual Notice of Right to Cancel form or can we just wait 3 business days from the date of the Change in Terms before we fund the new money?

Increasing HELOC-Send New Preliminary Docs?

12/23/2018

Do you have to send out new preliminary documents when increasing a Home Equity Line of Credit loan?

Is the NMLS# Required on HELOC Notes?

10/28/2018

Is the NMLS# required on HELOC notes?

Providing Periodic Statements After HELOC Matures

09/23/2018

I have been researching an issue for my bank in regards to providing periodic statements after a HELOC matures. Are FIs required to provide periodic statements post maturity on HELOCs? The Promissory Notes clearly states that the entire loan balance (principal and interest) is due and payable at maturity. I don't see it necessary to continue to send monthly periodic statements and this has also added confusion to the client. I do not see that this is addressed within Reg Z. Am I looking in the wrong place?

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Signature for Online Loan Application

11/17/2019

We have an online loan application that our members complete. It does not have a signature on it. We use that to pull credit, make the loan and the members come in and sign loan documents. My question is do I need them to complete a loan application in person with a signature or is the on-line application sufficient?

What counts for HMDA reporting thresholds

11/17/2019

Are all transactions that are HMDA reportable counted toward the thresholds?

Right of Rescission Rule Interpretation

11/17/2019

I need some help with the right of rescission rule interpretation. On a refi loan, if the borrowers receive all TRID disclosures on a Saturday but our offices are closed that day so their signatures would have to be made on Monday. My question is, when should the 3 day rescission period begin? On Monday- Wednesday ( based on disclosures received on Saturday) or Tuesday-Thursday ( based on the effective signing date of Monday)? Reg Z states: 1026. 15(a)(3) i. The period within which the consumer may exercise the right to rescind runs for 3 business days from the last of 3 events: A. The occurrence that gives rise to the right of rescission. B. Delivery of all material disclosures that are relevant to the plan. C. Delivery to the consumer of the required rescission notice.

Reason for Suspicious Activity on SAR

11/10/2019

We have a customer who asks for random people's help by having them issue checks to him and he provides them cash (more than the amount on check) in return. For us, it's suspicious but don't know what is the best reason to put in the SAR?

Open-end or closed-end?

11/10/2019

How are lines of credit that do not revolve treated; are they open-end or closed-end?

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