01/07/2008
Does a non-owner occupied HELOC applicant require a rescission period at closing?
12/17/2007
Would a first lien home equity loan be excluded from the general limit for extensions to executive officers?
11/26/2007
Who should receive the early HELOC disclosures and booklet? The loan is a HELOC for the purpose of college tuition. The student/daughter is the borrower on the loan and the father is co-signer on the loan. The collateral is the primary residence of the parents (both listed on the DOT) and the ROR was given to the daughter, the father and the mother.
10/22/2007
What am I requried to disclose in an outside banner for a HELOC? We want to feature a 4.99% APR, which is a promo rate. How much disclosure do I have to put to get this done?
10/08/2007
We would like to roll out an additional feature for our HELOC accounts which will require the borrower to sign an amendment to their original credit agreement. Given the number of banks we have acquired, we have quite a few versions of previously executed credit agreements on file. There are many different names for the credit agreements and some contain disclosure of the feature we would like to add, while others do not. How do we word an amendment so that it legally amends a specific borrower's credit agreement when we can't be certain of the exact name of the credit agreement to reference? If we can't be certain that the credit agreement contained disclosure for the new feature, is there any harm to having all borrowers sign an amendment when they request this feature even though they may be agreeing to the terms twice?
10/01/2007
Are reverse mortgages HMDA reportable? For example, a qualified borrower owns a home free and clear with a reverse mortgage loan taken out based on equity in the home. Second example, a qualified borrower has an existing mortgage balance on the primary residence and a reverse mortgage loan is taken based on equity in the home and part of the loan is used to payoff existing mortgage where borrower receives the remainder of the loan.
08/06/2007
I have an originator who wants to take an auto as additional collateral on a HELOC to cover a collateral shortfall. Would we have an audit issue?
06/04/2007
When you close a HELOC along with a purchase transaction do you rescind the HELOC? If so, how?
03/26/2007
We are looking at offering teaser rates on our money market and HELOC products. Can you please briefly discuss the disclosure requirements and regulatory references that should be reviewed?
02/26/2007
HMDA is clear that reporting HELOCs is optional, but it is unclear on whether all lines of credit are optional including unsecured lines made for home improvement purposes. I would assume that if we don't classify these as home improvement loans they would not be reportable. Would you agree? Also, if these lines of credit are originated by a broker specializing in home improvement loans and a potential notation of purpose is made on a non-bank application, would they still be non-reportable if we don't classify them as home improvement? Generally, it's my opinion that if reporting a HELOC is optional then any LOC would be optional. What's your opinion?