Most Popular Lending Content
Rescission on HELOCs
01/19/2004
We routinely cross-sell HELOCs to purchase money mortgage customers, and close them simultaneously with the purchase money first (although HELOC funds are not used for the purchase). Our review of Reg Z seems to indicate that these HELOCs are subject to the 3 day right to cancel, even though at the time of closing, the borrower does not live in the home being purchased. Are we interpreting this incorrectly?
RESPA Disclosures Given BEFORE Application
01/19/2004
With respect to a real estate loan, we have a Loan Officer who completed and mailed the RESPA Disclosures prior to application date. They think they should not have to mail out any additional RESPA disclosures after we received the application because they had already been given. I question how they knew what figures to use since there was no application giving them the needed information.
Disclosures of Fees on Commercial Loans
01/19/2004
Our sister bank was told by their examiners that they were in violation for not disclosing fees such as overnight fees on commercial loans. What fees are required to be disclosed in this instance? We typically list the loan fee and flood fee on the note under Additional Charges. What, when, where should we disclose on a commercial transaction (real estate and non-real estate related)?
1-8 range loan grading system -- John M. Floyd & Associates
01/05/2004
We currently grade our loans on a 1-7 range system. At a recent conference I was introduced to a 1-8 range grading system. I would like to get a copy of the spreadsheet of this system if you have one. Also, are examiners now looking for an 8-grade system instead of a 7-grade system?
Customer Credit Report Disputes
01/05/2004
What is the best way to handle a customer dispute regarding information we have reported to the credit bureaus? Should we handle the dispute or refer the customer to the bureaus and work with them? Why?