Participation and LIFO Loans
Our bank has noticed recently that the NADA website that we typically used for car and truck values has changed their formulas and the values are coming in are 20% to 30% different than the old values, depending on the make and model of the vehicle. I know that JD Power had recently purchased NADA, which may account for the difference. I am wondering what other lenders use for collateral values on vehicles now.
When making a new CD secured loan of $50,000, our aggregate exposure with the borrower will be $1,500,000. The bank's board has delegated lending authority to the underwriter of $650,000. Does the underwriter have the authority to approve this loan secured by the CD or does it have to be approved by the Loan Committee due to the aggregate debt?
If the borrower receives funds as the rep payee for his disabled brothers, can that money be counted as income for the borrower when completing underwriting?
We have an existing construction loan that we would like to increase. Will this have to follow TRID rules or can we do a modification to increase the loan amount, charge a 1% loan fee on the new proceeds, add filing fees, title fees and any other fees that may be associated with the modification?
Can an individual loan accommodation for a personal, family or household purpose to an existing borrower with other business loans be considered non-consumer?
Is there a regulation addressing the changing of payment due dates on installment loan? I'm not sure if this is federally regulated, state, or both. Is there a limit on the number of times customer can request, and the length (number of days) it can change?
We receive submitted applications from our website that are considered complete per TRID. Upon receiving the submitted application, we attempt to directly contact the applicants by phone or email regarding the application and items needed to make a loan decision.
If we do not receive any contact from the applicant, what are the notification requirements? Should the app be considered incomplete and we send a Notice of Incompleteness and if there is still no response by a certain date, we can close the file? Also, what would the timing requirements be to send the notice and then to be able to close the file?
We have had recent discussions regarding the rescission rules when applied to a TRID real estate purchase transaction. As the bank, we are financing the purchase of a new home; however, the consumer is using the home being purchased, as well as an existing property as collateral on their loan transaction. The use of an existing property is triggering the 3-day rescission period.
Per Kentucky law, a purchase transaction should be closed by an attorney. However, our lender is questioning whether or not consummation of the loan with the bank and the settlement by the attorney actually need to be dated the same day. He wants to close our loan 3 days prior to the closing with the attorney, so all funds will be available at said closing.
Is there a regulation you can cite that requires the loan transaction to be closed on the same day as the real estate settlement? I believe there are stipulations in regard to these requirements but having difficulty citing the reg.
Are Banks required to pay interest on a mortgage escrow account with a balance of $25,000.00 or more?