11/08/2020
We are in the process of developing a Jumbo HELOC product. There would be no fees associated with this product, but there is an annual fee of $90, interest-only payments and the balance would come due in 5 years. Considering the balance due in 5 years, would this product be subject to Ability To Repay?
08/06/2020
We have a customer requesting a HELOC instead of a short term construction loan in an attempt to avoid the draws. After construction is complete, a closed end mortgage would be provided. Since there is no equity in the home at this point, because it is not built, are we able to offer a HELOC for their home construction? Also, since they plan to pay off the HELOC at the end of construction, does the requirement for "repeated transactions" apply?
07/12/2020
We have a customer who has a home equity loan. We found that about $8,000 in draws which were not posted to his account from a year ago. His loan is now almost maxed out. Is it too late to charge his account? Is there a time limit to correct our error?
06/07/2020
If a customer uses a HELOC access check to advance funds, does a transaction
description other than "Advance" need to appear on the periodic statement?
04/05/2020
XYZ is our service provider for mortgage loans. They are telling us that there is no way to split out the daily interest to only calculate it based on the initial draw at closing. The system is going to calculate interest owed on the total available balance of the HELOC.
Our core provider cannot charge prepaid interest on the full amount of a HELOC, just the total of the first advance. So they are both different and it does not seem permissible to charge a customer money on something they have not borrowed yet.
Please let me know if XYZ can even accrue on the full amount?
02/16/2020
Is the servicing disclosure required on Home Equity Lines of Credit?
09/08/2019
Can a Home Equity Line of Credit be done for a borrower who has PMI insurance on their first mortgage?
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?
05/12/2019
Our HELOCs are tied to prime. We disclose that. If prime increases do we need to send rate change notices?
03/03/2019
Is there any reason why we are not allowed to have First Reserve/LOC statements and HELOC’s to be estatement?
