We are refinancing a 1st mortgage loan and 2nd mortgage loan(HELOC) to a new rate & term 1st mortgage loan to stay in our portfolio. Both are held in our portfolio now and no new money is being added, just principal balance with costs being paid by borrower at closing. Is a right of rescission required for this transaction?
How is the best way to handle when a customer wants to term out a HELOC? Can it be accomplished by a modification or should it be considered as a new request? If new request would HMDA be applicable?
What disclosures are required when you convert a variable rate HELOC in default to a HELOAN (fixed rate) and then back to a HELOC (variable rate) after a specific length of time? Can you do this?
Will the new HOEPA/High-Cost mortgage requirements due in 2014 prohibit interest-only payments for HELOCs?
A borrower goes to a branch to obtain a cash advance on their HELOC. If the teller uses a withdrawal slip to withdraw from the line instead of a bank printed check to document the loan advance, what is the risk to the bank?
We have a Home Equity Loan product in which the bank pays the fees. Must we disclose those fees as finance charges (POC) to get the correct APR (as opposed to excluding them from the TIL which is an option in our system)?
Does a Title insured open-ended HELOC require the completion of a HUD-1, and if so, does the Loan terms section need to be completed?
Our bank charges a $250 loan origination fee on our HELOCs. Should this be disclosed as a finance charge on the HELOC credit agreement and disclosure? What if the bank pays the fee upfront but will charge it to the customer if the loan is paid off within 2 years?
Can a home equity line of credit be calculated on a 360/360?
We currently have Home Equity Lines of Credit (open ended) that have floor rates of 6.00% and 7.00% and we would like to reduce these to our new floor rate of 4.25%. I know under Reg Z Section 226.5b (f) it states we can make a change that will unequivocally benefit the consumer throughout the remainder of the plan. With that being said what type of documentation and disclosures must be given in order to stay in compliance with the regulators and terms of the loan? We want to ensure that if we do a modification agreement on the HELOC we do not need to redisclose on the loan.