01/28/2018
If we disclose a general lender credit on the Loan Estimate sent to the borrower, can we remove the lump sum lender credit and make it a specific lender credit? Or are we bound to give the lump sum credit because that was disclosed and not itemized to a specific fee up front?
01/21/2018
Does TRID apply to HELOC's? Do I need to have LE's out within 3 days of an application?
12/31/2017
My question is regarding earnest money deposits on a residential mortgage real estate transaction. The file contained a copy of cancelled check from borrower to realtor dated 2/23. The application was after that date and intent of notice to proceed has not yet been obtained. Internal mortgage compliance audit cited violation of 1026.19(e)(2) stating check to realtor should have been dated after ITP. I think they are wrong - since that independent transaction happened outside of the control of the financial institution. I don't believe the EMD date preceding the ITP argument has any merit. Am I wrong? Do you have some advice on how to write some fun (but respectful) rebuttal language?
12/10/2017
Are Home Equity Lines of Credit included in the new loan originator compensation rules? If so, can an employer incent a loan originator based on the amount drawn versus the line amount?
11/19/2017
Where on a Loan Estimate would I put the fee for e-filing a mortgage?
11/12/2017
On a RE Refinance with cash out if you disclose the LE and then the appraisal comes in lower than expected and the loan amount changes (goes down) but the IR stays the same and the APR is still in Tolerance do you have to re-disclose the LE?
10/29/2017
During a recent audit of a loan file it was discovered that the initial mortgage disclosures were never given to the borrower. Being as we are already out of compliance would it be best to disclose now or leave the disclosures missing?
10/22/2017
We have a builder that gives a seller concession on all of their contracts. If the seller concession is more than the buyer needs they do not want us to reduce the seller concession amount. As long as we are not over the allowed percentage for VA/Conventional Seller Concessions, can we apply the balance of the remaining credit as a principal reduction?
We are trying to prevent reducing the loan amount at the 11th hour.
10/08/2017
How accurate does a Loan Estimate need to be?
We have an FHA loan that requires a 3.5% minimum investment and that homeowners insurance and real estate taxes have to be escrowed. Also, the Mortgage Insurance Premium is financed into the loan.
The Loan officer issues a Loan Estimate that :
1 does not reflect the minimum investment required in the Estimated Cash to Close line
2 does not reflect escrows
3 does not reflect that the upfront mortgage insurance premium is financed into the loan, and
4 the APR was inaccurate because of the above items not being on there.
Processing is arguing that since the application is accurate, it’s not a big deal that the LE does not contain accurate information for the borrower.
Is it important that the LE be accurate in reflecting these areas of information?
09/24/2017
Would we need to cure TRID if the transfer of deed taxes paid by the seller was not disclosed as a borrower paid fee on the LE for a purchase of residential lot loan?