The Reg. B requirement to deliver a copy of the appraisal is limited to first lien loans. The Reg. Z appraisal requirement is for HPML loans, and QM loans are exempt. Is there any requirement to deliver a copy of the appraisal on a HELOC or a fixed rate second lien mortgage loan that is not a non-QM HPML loan?
What is the specific requirements that a small bank has to meet for a customer that is 30+ days past due on a mortgage? For example, booklets, service members relief notice, etc.
The HUD Counseling List that we provide at the time of a real estate application shows the date it was printed on the bottom of the list. Does this date have to be within three days of the application?
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.
Is the List of Homeownership Counseling Organizations exempt on a homestead loan on property of 25 acres or more?
Our Bank has implemented a procedure of keeping a second copy of the Homeownership Counseling Notice. The copy is date stamped and retained to prove that one was mailed. Is this necessary?
Should a delinquent mortgage loan receive both a Homeownership Counseling Notice AND a Right to Cure Notice?
Is a Homeownership Counseling Notice required, if the deed of trust on a personal residence secures a commercial loan? Is the Notice required if the deed of trust is taken as "an abundance of caution"?
We have a borrower that is frequently past due 30 days or more on her conventional mortgage. In all of the Homeownership Counseling material we've read, we can't seem to determine if the counseling letter is necessary every time the loan is 30 days delinquent or not. Is is like the Right to Cure, where it only needs to be sent once, or should it go out every time?
Does the revival of the homeownership counseling requirement apply to commercial/business purpose loans that are secured by the borrower's primary residence?