Under current HMDA definition is a mobile home that is attached to real estate considered a 1-to-4 family dwelling or is it manufactured housing? In my opinion a mobile home affixed to real estate is more similar to housing manufactured off site and delivered/affixed to the land than a home that was traditionally stick built on-site. However, a mobile home does not meet the technical HUD definition of manufactured housing either.
Where do you put the fee on the GFE and HUD for e-filing a mortgage? I read commentary that it should go in the 1100 series but that seems odd if it is a HUD1-A.
I'm receiving conflicting information regarding the ability to use Paid Outside Closing to cure tolerance violations on the GFE/HUD. In short to set the stage, we do not charge closing costs on our real estate loans. Excluding a changed circumstance where a re-disclosure can occur, can POC be utilized in all other instances to cure a tolerance violation? Example: Upgraded appraisal from drive by to full by same appraiser that isn't a changed circumstance, transfer tax error, etc? If so, how would you indicate it on the HUD? In the example of an appraisal, would you show two appraisals being performed on the GFE column of the HUD and then show the one appraisal on the HUD column and a POC appraisal. The intent is to avoid cutting a check to a borrower on a no closing cost loan.
Has anyone heard when we might expect a new HUD Form 92070? It is set to expire 11/30/2014
Our bank is financing the purchase of a home. Buyers are currently renters and are now purchasing from the estate. Buyers do not have the required 20% down payment so they are entering into a second mortgage loan with the Sellers/Estate.
The initial disclosures did not mention the $30.00 mortgage recording fee for the mortgage the Buyers and Sellers will have between them.
Do we have to re-disclose because we did not list the private party loan expenses?
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.
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>
Can the hazard/flood insurance premium and property taxes be shown as a POC item on the GFE? We require that the borrower provide proof of insurance and taxes paid prior to loan closing.
Our bank was told that we must include an amount for title insurance premium on the GFE and HUD even though we do not require it. Is this true?
Do mortgage closing loan documents need to contain the loan number on the document (i.e. HUD, initial escrow disclosure statement, notice of right to cancel)?