11/10/2014
We have a first-lien HELOC at 80% LTV. We want to offer a second-lien closed-end home equity loan at 20% LTV. Since the two add up to 100% LTV, are we required to escrow? Neither loan is a higher-priced mortgage. The first is below 1.5% APR over APOR and the second is below 3.5%. Do I need to escrow?
07/15/2013
We were notified several months ago that a customer died. She had a checking account and a home equity loan with us, both singly owned. We have locked the checking account so no activity can occur on the account until we receive the proper paperwork from the PR of the estate. No payments have been made on the home equity since the death of the customer and now loan servicing wants to debit the checking account to bring the loan current and then to debit the account monthly for the payment. Is this permissible or advisable?
07/15/2013
Does the HUD Special information booklet have to be provided for Home Equity and Home Improvement loans? From looking at Regulation X I would say yes, but I can not find any true guidance. When looking at the booklet, it does talk about Home Equity loans but it doesn't mention Home Improvement loans.
07/01/2013
These are general RESPA questions that have recently been proposed by Management and we would appreciate your expertise.<ol><li>Do we have to itemize Hazard Insurance on the GFE for a home equity loan when the Hazard Insurance is already in place? It is my understanding this is a requirement on the GFE because we require the Hazard Insurance to be in place before making the loan therefore it is a cost of the loan.<li>If all the fees are paid by the lender except for the origination fee, do we need to itemize each fee paid by the lender on the GFE? Doing this gives the wrong impression to the customer that they will owe fees that they actually won't have to pay.<li>If your answer is yes to #2, could we show a credit on the GFE for the fees being paid by the lender? Doing so would bring the final fee disclosed to reflect the actual amount being paid by the customer. Another related-question would be what line would the credit be reflected on the GFE? </ol>
06/10/2013
Husband approved for home equity loan - in HIS NAME ONLY. Deed ownership in HUSBAND & WIFE, Both sign the mortgage and right to cancel. Identified her with a PA Drivers License. My supervisor wants her SS# too. (Wife is not a client of the bank or a borrower). Is the wife obligated to share her SS# with us?
05/06/2013
These are general RESPA questions that have recently been proposed by Management and we would appreciate your expertise.<ol><li>Do we have to itemize Hazard Insurance on the GFE for a home equity loan when the Hazard Insurance is already in place? It is my understanding this is a requirement on the GFE because we require the Hazard Insurance to be in place before making the loan; therefore it is a cost of the loan.<li>If all the fees are paid by the lender except for the origination fee, do we need to itemize each fee paid by the lender on the GFE? Doing this gives the wrong impression to the customer that they will owe more in fees.<li>If your answer is yes to #2, could we show a credit on the GFE for the fees being paid by the lender? Doing so would bring the final fee disclosed to reflect the actual amount being paid by the customer. Another related question would be what GFE line would the credit be reflected on?</ol>
05/06/2013
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)?
04/22/2013
Can a home that is attached to a condo and a duplex be pledged as a home equity request?
04/15/2013
I know that principal dwelling on 25 acres or more is exempt from RESPA, but do you still consider it as a higher-priced mortgage loan under REG Z or can we treat it like a commercial loan?
04/08/2013
Can a home equity line of credit be calculated on a 360/360?