We did a purchase money primary residence for 6 months paying interest monthly. At closing, customer changed payment at maturity. Do we need to give a new TIL disclosure? The APR went from 4.983% to 4.991%. Lender says we do not because it is less that 1/8 of 1%. I think we do because she changed the payment schedule.
On home equity lines of credit, how far in advance of payments must the billing statements be sent? If a bank chooses to make a change in the number of days must the customer be notified, and if so, how far in advance?
Loan extension agreements. Where can you find the forms? What disclosures are required when a maturity extension is given, no change in interest rate and no new money advanced?
If two individuals own a dwelling and have a loan that is secured by the dwelling and one purchases the other's interest in the property, with a dwelling secured loan, is that reported on the HMDA LAR as a Refinance or a Purchase?
Our examiners are questioning the way we applied a double loan payment. One month our customer made two loan payments on the same day that satisfied that month and the next (lets say January and February). They made no payment in February, and made the next payment in March. The payment was applied to interest through that day, the escrow account, and the excess to principal. The examiners say we should not have had 2 months interest due in March (60 days) even though the payments were 60 days apart. They are worried we claimed too much income, although it works out to less income to us and more principal reduction to the borrower. How do we need to change how we apply the payment as they cannot tell us?
Is a home purchase exempt from HPMLs?
Is it permitted to use someone else's savings or CD account (borrower isn't a co-owner) for collateral on a loan?
When you place a loan on non accrual, can you still assess the late charge fee?
HMDA question: I have a customer that is doing a refinance of her property to pay off credit card debt and to buy out her sister's interest in the property. The property is owned free and clear. The customer and her sister both hold title. I do not think it is HMDA since we are not paying off a dwelling secured property.
We have a customer who lost her husband and is needing to take out a loan to cover the funeral costs. We will be using their mobile home, which is their primary residence, as collateral. My question is; can we conclude that this circumstance is a bonafide personal emergency for the purpose of waiving the three day right of rescission?