For TRID purposes, is a construction loan considered to be a purchase money loan?
When pest treatment is required and if the seller is responsible for that cost, does that still constitute redisclosure of loan estimate?
We are moving to offer higher rates and eliminate origination fees to include broker fees when a broker is involved. Instead we would pay the broker upfront, and hopefully collect that fee in interest over the next several years. Do we have to disclose the broker fee as a lender paid item POC, or do we eliminate it all together?
Based on the TRID amendment effective 10/1/18, if a consumer decides to increase a loan amount after the initial loan estimate has been issued, is a revised LE required to comply with the new tolerance for Total of Payments disclosure?
We have a TRID, 62-month balloon loan that has gone past its maturity. Do we now have to treat this loan as a refinance? Does the borrower have to complete a new application or can we issue a Loan Estimate with the earlies, issue the CD (comply with the 7-day waiting period) and have the borrower sign an extension?
Let's assume an applicant applies for a 15 year fixed rate loan that is offered by our secondary market investor, but the loan request does not meet investor's program requirements. We counteroffer with our own 15 year fixed rate product. The differences between the products are different fees, different underwriting standards, and servicing sold vs retained. Both are 15 year fixed rate loans, but different products. If the counteroffer is accepted, could a revised LE be issued for fee tolerance issues?
Our state pays real estate taxes semi-annually. Can we charge a "life of loan" fee on consumer real estate loans for performing a real estate tax check? If we can charge such a fee, must it be incorporated into the loan origination fee (which we currently do not charge) or can it be a separate line item? If a separate line item, where does it get placed on the LE/CD?
We are a small credit union with about 4,000 mortgage loans. We are beginning to accept payments online for the application and for the appraisal fees that are required. Are there any restrictions on using an outside vendor to do this for us?
Is a rate lock agreement necessary now that the TRID loan estimate includes notification that the rate is locked?
Do we need to send a Good Faith Estimate on a new HELOC, or would this need a loan estimate and a closing disclosure?