We are auditing home improvement files. Here is the situation: An advancing line of credit is issued on a home improvement loan secured by the dwelling for approximately 3 months. A renewal (not a refinance) of the loan is done at the completion of the improvement. The changes to the loan agreement consist of payments and maturity date. The interest rate remains the same.<ol><li> How and what do we disclose on an early TIL when the loan opens at a zero balance and no advance dates or amounts are known?<li>If so, what do we disclose on the renewal?<li> Can you point us to the part(s) of Regulation Z that addresses this situation?</ol>
Is there a 12 day cooling off period for home improvement loans?
Can you have a home equity loan and a home improvement loan on the residing homestead?
When would the Right of Rescission begin in the following scenario? This involves closing of a home improvement loan. The situation is out of the norm, where documents were taken out of the attorney's office for additional signatures. Customer comes in November 15th to sign papers. However, in this case, a second signature is required on the deed of trust only, not the note, which also must be notarized and the right of rescission notice must also be disclosed to this individual. All documents in question were taken for signature. If upon return of documents, the Rescission notice was dated showing receipt as of the 15th but the D/T was signed and notarized 2 days later, for example on Saturday Nov. 17th, would your rescission period begin the Friday Nov. 16th or Monday Nov. 18th. I believe ROR should begin the latter to occur of consummation of loan documents (signing the loan documents), delivery of ROR notice or delivery of material disclosures. In this case, applicant's signing)
I have an application for a loan to remodel the home the applicants live in. Will they need to be given a Right of Rescission? I was told any time the primary residence is taken it is yes. But I was also told if it was less than a year - then no. - This loan is for 9 months.
When is it not necessary to collect monitoring information, and when necessary?
Someone came back from a seminar saying that for a Home Improvement Home Equity the early truth and lending is not required. Is this true and if so where can I find that in the regulations?
In regards to HMDA Reporting. If a loan is for the purpose of home improvement and the term of the loan is less than 24 months is the loan HMDA reportable? HMDA is based on the purpose of the loan, not the term?
We have an application for a loan to purchase a residence which is secured by another dwelling owned by the applicant. What do we record in the property location section of the HMDA LAR?
If compliance specialists got a nickel for each time they answered a question on what loans are covered by which regulations or rules, we'd all be in a higher tax bracket.