12/31/2023
The initial and locked Loan Estimate (LE) on an ARM loan was based off the WSJP index. When it was time to issue the initial Closing Disclosure (CD), the WSJP index had increased causing the APR on the CD to be about 1/2% higher than on the last LE. Should we adjust the index value on the CD to match the index value used on the LE to keep the APR within tolerance, or do we need to update the index value to the current value and redisclose the LE and then inssue an initial CD?
09/17/2023
Can you do a HELOC on a home a customer is buying? The first draw will be to complete the purchase.
The house has a purchase price of $90,000 and they need to borrow $30,000. They don't want all the expenses and hassle a regular mortgage entails. They want to just take out a HELOC on that new home. A HELOC is not TRID so we would not need all the documention either.
08/20/2023
Generally a bank charges a set flood certification fee around $18.00. It is identified as flood certification on the Loan Estimate and Closing Disclosure. No other flood fees are assessed. The actual flood amount charged is $13.25. The FDIC has never had a problem with this. Is that markup a violation of RESPA or another requirement?
06/11/2023
We added a co-borrower to our loan and sent a revised Loan Estimate to this co-borrower, but not initial disclosures. Are we out of compliance? Is there any way to cure this before loan closes if it is a problem?
05/28/2023
This is for a TRID - Lot/Land loan. Is an Irregular payment schedule with 12 months interest only payments followed by a payout term (ex. 24 months P&I with 108 months amortization, and any balloon) allowed?
03/19/2023
On the loan estimate, I input it as a balloon rather than installment which drastically increased the payment. Do I need to redisclose theis with a revised LE or do I make the correction in the closing disclosure?
03/05/2023
I have an auditor questioning the timing of the revised Loan Estimate and loan consummation -- I informed auditor that borrower was sent revised Loan Estimate four business days prior to consummation and that is in line with
the regulation; and the 7 business days requirement references the initial loan Estimate (not revisions) --- Am I understanding the regs correctly or not?
02/26/2023
I have an auditor questioning the timing of the revised Loan Estimate and loan consummation. I informed auditor that the borrower was sent revised Loan Estimate four business days prior to consummation and that is in line with the regulation; and the 7 business days requirement references the initial Loan Estimate (not revisions) --- Am I understanding the regs correctly or not?
12/25/2022
We have a builder in one of our markets who is the seller on one of our transactions. He wants to pay to buydown for the borrowers interest rate. This would cause us to go over the points and fees threshold. My question is, would a seller paid amount to take the rate down be exempt from the points and fees calculation?
11/27/2022
If a revised Loan Estimate was provided to include a second appraisal and a clerical error added a $6,000 lender credit, can it be removed/corrected?