10/20/2003
Our bank is going to participate in a buy down program. For R/E and consumer loans if a customer comes in and wants to get a lower interest rate, we will charge a 1% buy down fee. What disclosures are required, if any? We aren't refinancing, a new note won't be issued. The monthly payment will not change either. I have found a blurb that states "an adjustment ot the interest rate on a loan with a term greater than one year secured by the consumer's principal residence requires that a disclosure of the changes be provided to the consumer. It must state the following: current and prior interest rates, index on which rates are based, extent to which the creditor has foregone any increase in the interest rate and what the payment will be due after the adjustment and the loan balance."
09/15/2003
With respect to the Soldiers and Sailors Civil Relief Act (SSCRA), I understand debts incurred prior to entry into the military are subject to the 6% interest rate cap. Does it matter whether or not the military member voluntarily enlisted in the military? I thought the SSCRA would apply only if someone was drafted into the military.
09/02/2003
I am the internal auditor at our bank and am currently reviewing lending operations. I am seeking to determine if there are any regulations or statutes that limit or prescribe amounts that can be charged borrowers as late fees for delinquent loan payments.
05/08/2003
02/02/2003
If we lower the interest rate and change the note from a fixed rate to a variable rate mortgage, do RESPA and Reg Z apply? Does it matter if the collateral is a primary dwelling or just a second home?
11/01/2002
The penultimate session at PCi's CRA and Fair Lending Colloquium was a discussion and debate on payday lending.
09/02/2002
Is it alright to fax a mortgage rate sheet to realtors once a week that does not have the APR on it, just the rate?
08/01/2002
HUD has published a proposal to make significant changes to the Good Faith Estimate that lenders issue within three days of taking an application. HUD calls this a "simplification" of the GFE.
07/01/2002
Is there a simplified summary of the current, pending HOEPA changes/regulations, pertinent to a mortgage nondepository lender?
07/01/2002
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>