03/11/2002
Our bank is interested in obtaining a blanket lenders single interest insurance policy. I would like information on what amount of the premium could be passed through to the consumer, and if that amount would be need to be included in the finance charge?
03/11/2002
Our bank has a separate mortgage subsidiary that originates all of our mortgage loans. We wish to begin mortgage lending to insiders, but to keep it arms length, will assign all such loans to an investor immediately at closing, and all will be sold service-released. Is it still necessary that a clause be included in the note per Reg.O sec. 215.5(d)(4) giving the bank the right to call the loan if the insider becomes indebted to other banks in an amount greater than the limits imposed by the the regulation? Under these circumstances, it doesn't seem to make sense.
03/11/2002
We have always required borrowers of unsecured credit to purchase credit life insurance from a company we have always done business with. While reading some information on "Consumer Protections for Depository Institution Sales of Insurance" I ran across some information that suggested we can not "require" a borrower to purchase credit life insurance. Is this true? Also, customers request credit life insurance on other types of loans, do we still have to give the insurance disclosures on these types of loans? Can these disclosures be added to the bottom of a loan application?
03/11/2002
For consumer construction loans that are RESPA related, how do we complete the HUD 1 regarding full disclosure of third party fees, for example inspectors, if we close prior to knowing who will be performing the inspections?
03/04/2002
Our bank is interested in adding verbiage to include "pre-payment penalties" on our commercial loans. What are the required disclosures and what are our options for structuring?
03/04/2002
What is the "official" definition of the lending word "refinance"?
03/01/2002
03/01/2002
02/11/2002
On the Good Faith Estimate and the HUD1 Settlement Statement, what is the appropriate line for property taxes paid outside of closing and flood determination fees (we use two lines for this)? Also, is the right to receive a copy of the appraisal notices required on business purpose loans secured by residential property, such as loans to builders?
02/11/2002
When is it not necessary to collect monitoring information, and when necessary?