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?
I have a lender telling me that the borrower was considered to have shopped for services because the provider listed on the Settlement Service Provider List (SSPL) has 3 office locations and the borrower went through a different office location than that disclosed on the SSPL. The lender believes going to a different office address is considered "shopping." I don't agree, but would like clarification on this.
We have a loan that is going to be secured with acreage and a modular home. The value of the land is greater than the value of the modular home. The land is used for agricultural purposes but the modular home is going to be the primary residence. Would this fall under a consumer TRID loan or an agricultural loan?
How should we disclose construction loan inspection and handling fees?
We are doing a TRID mortgage loan and the LE was sent a while ago. We now need to add his wife to loan. Do we need to have her receive all those initial documents we sent him? She did do an application.
We are having a debate as to what is the baseline for 10% tolerance fees when there are a number of LEs and CDs where fees have decreased. Is the baseline the first LE that may have a total of $2500 or the latest disclosed LE or CD that may have a total of $2000? The regulation seems to only address resetting baseline when fees increase rather than when fees decrease.