02/20/2012
Do you know where I might go or who I would contact to ask questions concerning the High Priced Mortgage Loan requirement? We have a first mortgage loan that re-prices every 60 months with a 30 year maturity. The loan is based on WSJP + index. The parameters set up in the APOR do not fit our loan type?
02/13/2012
If the rate spread on a 2nd home is greater than the 1.5; are you required to escrow taxes and insurance on a 2nd home (not primary residence)?
01/23/2012
We have a consumer purchase of a 1-4 family dwelling where the initial rate offered put it into the HPML category. The customer has negotiated a lower rate after the initial docs went out. We have redisclosed. What lock date is used to refigure if it is still HPML? Is it the original lock date or the date the new rate was renegotiated?
01/09/2012
Is a HPML to a trust covered by RESPA? It is to be the primary residence for the trustees. Reg Z exempts loans to other than a natural person, but we need to be sure.
10/24/2011
Can an agreement for waiver of escrows be signed so that a customer can waive the required escrows on a 1st lien Home Equity?
09/05/2011
Is an escrow account required on a first lien, primary residence, mobile home loan but not on the land just the mobile home as collateral?
08/22/2011
Our institution is purchasing an HPML from another institution that originated (06.02.2009) before the new escrow requirements. Are we now required to escrow? Or is the loan "grandfathered" (not requiring escrow after purchase) because it technically originated before April 1, 2010?
06/27/2011
We have a request to renew an existing loan and add new money for repairs and improvements. Since it is a home equity, we would need to proceed with another new home equity. Presently, this loan is land only and was done as a home equity because a mobile home was later placed on this property for them to reside. Would we be required to escrow on this loan even though it is still considered land only?
05/30/2011
1.) What date do you use when using the FFIEC calculator to determine a higher priced loan (in-house loan) Is it the application date or is it the date that the loan is to be closed. 2.) This loan is a jumbo loan so would the same rule apply for a different threshold of 2.5 instead of 1.5% even though it is an in-house loan?
05/23/2011
Does an investment property fall under the guidelines for determining a high price mortgage? This is not a commercial loan.