Vendor Guru Q&A - Lending

Sharing Exception Reports with Lenders

Latest Lending - HELOC Topics

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?

HELOC Early Disclosure- Acknowledgment of Receipt

09/16/2018

For HELOC early disclosures (ex. appraisal notice, consumer credit score disclosure, acknowledgment of receipt of counselor list, home equity application disclosure,) is the borrower required to sign these forms to acknowledge receipt, or can we have copies and a letter listing them out as proof in the file that they were delivered?

Government Monitoring Info on 2nd Home HELOCs

09/09/2018

Do bankers collect government monitoring information on 2nd home HELOCs?

Send Good Faith Estimate on New HELOC?

08/26/2018

Do we need to send a Good Faith Estimate on a new HELOC, or would this need a loan estimate and a closing disclosure?

HELOC Under $250,000 as 1st Deed-Appraisal

08/26/2018

I am doing a HELOC for under $250,000 as a 1st Deed. Is a full interior appraisal required or can a desk-top valuation be done?

State ROR for HELOC is Open-End Loan? (Appendix G)

08/19/2018

Does a Right of Rescission for a HELOC have to state that the loan is an open-end loan? All the rescission forms in Appendix G include reference to an open-end loan.

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?

Premium Content View All

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.

Loan Created in Signers Name-Company Debt

10/14/2018

A customer is signing for a company and owns 25% of the company, if a loan is created in the signers name would the companies debt need to be included in aggregate debt?

HMDA GIR Mixed Use Properties

10/14/2018

We made a loan to a non-profit for the purpose of acquiring and renovating 10 different properties. Loan is construction - perm. Eight of the properties are residential and the other two properties are commercial. The majority of the square footage (about 72%) of the total square footage of all ten properties is commercial. The two commercial properties are strictly commercial (not mixed use). The commercial properties comprise about 39% of the net collateral value, although the majority of the property values are lender's valuations, and not actual appraisals. I've looked through the HMDA GIR and do not see where this situation is addressed, unless I've overlooked it. The closest situation I could find addressed mixed use properties. In those situations, it stated it was at the lender's discretion, citing use of square footage or value. So I have square footage leaning to commercial (exempt) and value to residential (reportable). Would this be HMDA reportable?

Home Equity Loan: Improvement or Cash Out Refi?

10/14/2018

We are brand new to HMDA due to purchasing a branch in an MSA. We will start inputting in 2019. Our question is, if we have a home equity loan (we do not do LOC'S on home loans), it is to refinance existing mortgage and other funds are used for improvements to the property. Would that be a refi, home improvement or cash out refi?

Closed-End Threshold Test: Count Purchased Loans?

10/14/2018

Do we count purchased loans for the closed-end threshold test to determine if we are a small filer under HMDA? 1003.3(c)(4) states that the purchase of an interest in a pool of loans is an exempted transaction under HMDA, however I do not think that this includes mortgage loans purchased as a pool of loans. Thank you!

Getting Escrow Statements in Sync

10/14/2018

Doing annual statements is a real pain every month. What can we do to make these easier?

Latest Lending - HELOC Topics

Pages

Pages

Pages

hot right now