Is there a specific waiting period to close from the date of the GFE?
Is a HELOC subject to any of the waiting period restrictions imposed by reg Z as of 7/2009?
If the APR change is greater than the tolerance of 1/8, how long do we have to send out the redisclosures to the customer?
If we give the early TIL the same date as the application, how soon can the loan be closed?
Is a HELOC that is not tied to a credit card or overdraft account, that is a fixed rate with fixed monthly payments required to have a periodic statement monthly?
For HMDA purposes, when an application is received by mail and the applicant selects that they do not wish to provide the government monitoring information but still answer the questions of ethnicity, sex and race should the bank complete HMDA as the information has not been provided or complete those questions with the race ethnicity and sex provided by the applicant? There are a few different opinions being given.
I was asked by a peer about "mortgage bot" application entered on the Internet that were not submitted and not complete to meet the 5 criteria to be a mortgage application (SS#, name, address, loan number and product). I was asked if they require a Reg B adverse action notice. I view them as an incomplete application which technically wasn't even submitted and not Reg B compliant. Am I right these are not applications and do not fall under the Reg B requirement of adverse action notices? They do not fall under HMDA requirements and I do not believe they should be reg B required either. If I didn't have a name or an address I couldn't mail them out even if I wanted to.
Do we need to complete the government monitoring information on the mortgage application taken over the phone or submitted by mail when the borrower has selected "I do not wish to provide"? If yes, do we use surname to make the choice?
Are we required to disburse a loan on the 4th day of the Rescission period? We have some lenders believing they can disburse the loan any time after the 4th day. As a result, I have run into problems such as when to date the loan on the system and what action taken date to use for HMDA reporting.
When a savings account is pledged as collateral, do all signers need to sign the pledge agreement or is only one needed?