Most Popular Lending Content
Charging a Fee for Returned Loan Payments
01/19/2004
We would like to implement a $25 returned payment charge when a loan payment drawn on another institution is returned to us NSF. This charge would cover our costs of reversing the loan payment and sending the NSF check back to the customer. When customers have a deposit account with us, we don't reverse the loan payment if the check is NSF. Instead, we just overdraw their deposit account and the overdraft charge is handled on the deposit side. As we cannot do that with payments drawn on another institution, we would add the $25 returned payment charge to their loan balance(not to the principal). What are the Reg Z or other federal regulation considerations for this? I do not see this specific situation addressed in Reg Z, and did not see anything on the BOL website addressing this either.
Failure to Disclose Odd Days Interest
01/19/2004
If a lender fails to disclose 15 odd days of interest on the Good Faith Estimate (either 10 or none) is a new disclosure required?
Application Defined for Early Disclosures
01/19/2004
When a borrower submits a request for a mortgage pre-approval (borrower intends to purchase, but has not identified a property), are we required to disclose with TIL/GFE? Also, I can not find a definition of Loan Application as determined by Reg Z. Where can I find this?
Payoff-Related Fees
01/19/2004
What fees are we allowed to charge for a payoff? We currently charge a fax fee and a fee to record the cancellation. Can we increase the recording fee to cover our cost of preparing the cancellation? Are we allowed to recover our payoff processing costs by charging payoff fees?
Determining Flood Insurance For Condo Units -- John M. Floyd & Associates
01/05/2004
We are having some difficulty determining flood insurance coverage for condo units. For example, loan is $500,000, condo association indicates coverage for $666,000 for the 4 units in the condo building. We obtain an appraisal that reflects a value of $175,000. Obviously, the land where the condo has significant value since it is a beachfront property. The insurance company will not issue additional insurance as they indicate there is enough coverage based on the replacement value, which the insurance company indicates is $159,000. We're inclined to require the customer to get the additional coverage to have at least the value of the unit. Are we determining this correctly?