Vendor Guru Q&A - Lending

Latest Lending - HELOC Topics

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?

Home Equity Term Loans

04/24/2016

On Home Equity Term Loans, are we required to Verify Employment as part of the Ability to Repay?

HELOC forbearance agreement and disclosures

04/10/2016

My question pertains to HELOC transactions, which are open-end credit secured by real estate. Does a forbearance agreement require a disclosure if an Equity Line Credit Agreement and Disclosure comes after the original maturity? Is there any resource or link directing me to a regulation?

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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.

Credit and Account Exception Tracking

05/20/2018

What's the best way to streamline credit and account exception tracking?

Disclosures for Construction Loan Extension

05/20/2018

On construction/permanent loans with one closing-upon completion, a modification is done and the 30 year rate is set at that time. There are times we have to extend the construction period of 12 months . Usually the rate remains the same but at present the rates are changing. The construction period we base the rate on is the WSJ prime +1% fixed for 12 months. I have to extend one now and the rate will increase from 5% to 5.75%. What if any disclosures are required at time of extension?

Renewal w/Vacant Land as Collateral-Evaluation

05/20/2018

Two years ago we granted a new loan and took a first mortgage on a piece of vacant land as collateral. The loan is now going through a renewal. While completing the evaluation, we learned that the borrower; using his own cash, built a home on the property that’s encumbered. The way our mortgage reads, we have interest in ... all existing or subsequently erected or affixed buildings, improvements, and fixtures... When we complete the valuation report, should the value of the home be included in the report and furthermore, if so, should the report be mailed to the borrower under Regulation B?

Content of the Shopping Disclosure

05/20/2018

Should homeowner’s/builder’s risk/flood go on the shoppers list?

Fair Lending - Redlining

05/13/2018

Redlining is an illegal practice under Fair Lending. Isn't it also illegal under the Community Reinvestment Act?

Latest Lending - HELOC Topics

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