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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?

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?

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.

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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Minimum Age to be a Member of LLC

09/15/2019

What is the minimum age a person can be to be a member of an LLC and if it is less that 18, does it impact that persons ability to borrow on behalf of the LLC?

MLO Transfers to Location: Updating Address

09/15/2019

If an MLO transfers to another location at the same institution or there is a change in the address of the location that the MLO directly reports to, how long does the MLO have to update the contact address on the NMLS consumer access site to reflect the (new) accurate address location? I couldn't find anything specific regarding a time frame within the regulation, and it only touched on the requirement of internally auditing, at minimum, annually to ensure accuracy.

Requirements when Lending to a Non-US Citizen

09/15/2019

Are there any specific requirements or restrictions when it comes to lending to a non-US Citizen?

Loan Docs Returned After the Note Date

09/15/2019

A question has come up after we prepared a Note for a commercial loan. It was dated July 15,, but the customer did not return these documents until July 22. We funded this loan and effective dated our loan to the 15th to match the Note. Now management is saying we should not have effective dated the loan, only the date we actually funded it. Can we do this, not just for commercial but also residential loans? What is the correct way to handle loan docs returned after the Note date?

Escrows, more than dirt

09/15/2019

While auditing a mobile home loan I saw escrow statements. Isn’t this unnecessary since RESPA doesn’t apply when we don’t have real estate as our loan collateral?

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