Can a lender purposely not get one of the six TRID items to avoid getting an application in order to delay the loan estimate delivery date?
How can the “compliance aid” provision be used?
Why are first lien home equity rates being measured against a residential Average Prime Offer Rate (APOR) when these are two different products? It is hard to explain to a borrower that their home equity rate is priced higher than the average rate of an entirely different product, thus resulting in an escrow requirement.
On our old operating system we provided a TISA disclosure to our business customers when they opened a certificate of deposit (CD). Our new operating system separates personal accounts from non-personal accounts and does not automatically produce this disclosure for a business customer. Only a CD receipt is generated for non-personal. It lacks interest calculation and detailed penalty information. The two products function identically. By providing our business customer with the TISA disclosure we are ensuring that they receive detailed interest calculation and penalty information. We think it's important for them to receive this information to avoid UDAAP concerns. Rather than reinventing the wheel, it seems simpler to give them a TISA disclosure. Do you see a problem with providing a TISA to our CD business customers?
Pertaining to the acceptance of private flood policies, my question is in reference to the statement found in the OCC Federal Register (vol. 84 no. 34 pg. 4955). “Specifically, the proposed rule … to mean an insurance policy that: (1) is issued by an insurance company that is licensed, admitted, or otherwise approved to engage in the business of insurance in the State or jurisdiction in which the property to be insured is located, by the insurance regulator of that State or jurisdiction or, in the case of a policy of difference in conditions, multiple peril, all risk, or other blanket coverage insuring nonresidential commercial property, is recognized, or not disapproved, as a surplus lines insurer by the State insurance regulator of the State or jurisdiction where the property to be insured is located.” Please confirm which state the licensure would be verified in. Is it in the state the real property is located in, the state in which the agent is, or the state in which the insurance company is located? For example: assume our real property is in Louisiana, the agent is in Texas and insurance company is in Massachusetts. My interpretation of this statement is we would verify licensure in the state of Louisiana, but it's confusing.