Under the Notice of Transfer requirements in RESPA, what is considered to be the definition of the "effective date" of the transfer? I understand that the transferor is required to provide the notice 15 days prior but I don't know if that is the date the payment is due or the date the loan is actualy purchased by the investor.
Are we required to disclose on our monthly mortgage billing notices the amount of the late charge and the date the loan will be considered late?
Where can I obtain software to compute historical table data for home equity line of credit programs?
A customer has requested Home Equity Line of Credit to be used partially as purchase money for new home. We would have 1st lien as remainder of purchase will be from customer cash. Do we treat this as a "Purchase Money Mortgage" with all appropriate RESPA and TIL disclosures, or will it qualify as HELOC with appropriate disclosures? The loan will not be closed until current home is sold, therefore, no bridge loan.
If a customer is paying off a first mortgage with a new home equity line of credit, do we need to disclose the first mortgage payoff in any disclosures?
Would it be more advantageous to take out a home equity line vs. a home equity loan paying off both at the same rate over the same period? Would the amortization be the same on both debt loans? I want to have the loan paid off in four years. My wife and I are having a dispute here. She says it doesn't make a difference, I say it is better to have a home equity loan vs. a HELOC. Again, the loan needs to be paid off in four years with equal monthly payments.
Our society has long accepted the fact that some people cheat. In fact, we assume that certain professions cheat.
On a refinance of a dwelling loan plus new money for debt consolidation, should this be reported as HMDA? In the publication A Guide to HMDA Reporting Getting it Right! pg A-6 "B" (1) Data to be excluded: Loans that, although secured by real estate, are made for purposes other than home purchase, home improvements or refinancing (for example, do not report a loan secured by residential real property for purposes of financing college tuition, a vacation, or goods for business inventory). This says to me that if the new money over the amount of the loan you are paying off is not for home improvement DO NOT report. However, appendix D of the publication mentioned above pg D-2 #2 Meaning of refinancing (iii) Assume that the new obligation is a refinancing of a home purchase or home improvement loans only if the new obligation will be secured by a lien on a dwelling. So is this saying, it does not matter what the purpose of any new money is for, if the old loan was secured by the dwelling and the new loan is secured by the dwelling, it is HMDA? As you can see, confusion rules with HMDA.
There seems to be some confusion regarding the new TIL for High Cost Mtges that go in effect in Oct. Is this new ruling geared towards Primary residents only, or does include investment properties and if so, where can I find the verbage that states just that. I am in the state of Florida.
Our bank is introducing a new Home Equity Line of Credit loan service. We are considering mortgage lending protection insurance for each line, and wish to pass the premium on to the borrower/s. This would benefit the borrower/s as title policies or certificates would not be required. How should this cost be disclosed under Reg. Z and RESPA?