Is a Truth-in-Lending disclosure for HELOC the same as the Initial Disclosure?
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or 2 – do we report the accepted closed end mortgage counteroffer as home improvements on our HMDA LAR as a withdrawn request?
On Home Equity Term Loans, are we required to Verify Employment as part of the Ability to Repay?
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?
When can you collect an appraisal fee for a HELOC?
I am looking for information on HELOCS, and my question is, as an industry standard, which is the average usage rate on a HELOC?
Is the homeownership counseling notice required for all HELOCs? I have seen the regulation, but I am also being told there was a loophole in the regulation that says this is not a requirement.
We are doing a Home Equity Line of credit to purchase a home, do we need to do TIL and GFE disclosures? Or are they exempt?
Is right of rescission required on a refinance of an existing HELOC if there is no new money and renewing loan to extend the maturity date?
What is the 3-day rule when a HELOC is being converted into a HE loan? I'm in Operations and we have problems when a loan officer starts a Presentation without including us and then sends us the information about a month later. Do we concern ourselves about not getting the information early enough to send the preliminary disclosures within the 3 days? This is an ongoing problem that we would like to settle once and for all.