Most Popular Lending Content
Home Equity Rate Special Disclosure Details
12/08/2019
Can we remove some of the details in a home equity rate special disclosure for billboard advertising and replace with a toll free number?
Commercial with Collateral as Operating Interest
12/08/2019
I have a commercial loan with collateral as "operating interest in wells." Do we need a mortgage, UCC or both to perfect a security interest in this? Also, is this collateral even considered real estate collateral?
HMDA- Primary Residence Used to Purchase 2nd Home
12/01/2019
We have a borrower that is using their primary residence (that does not have an existing lien) to purchase a second home. If I am understanding Reg C correctly, I would be reporting the loan as a purchase because that is what the funds are being used for. Would I then report it as a primary residence because the property that will have the lien is their primary residence or would it be a second home because that is what the funds are being used for?
Delivery of a Closing Disclosure by Email
12/01/2019
In search for further guidance on compliance for delivery of a Closing Disclosure (CD) by way of email (with a borrower's E-Sign consent) we have varying differences in the interpretation of the word "Receipt". It has been our department's practice to deliver the CD within no less than 3-business days prior to closing. Documentation to evidence delivery has been by including a printed copy of 1) email showing our department's delivery of the CD to the borrower by way of email, and/or 2) a printout showing the "Arrival Date" of the email/attachments to the borrower. Some have interpreted the "Receipt" rule as evidence the email and attachment(s) was "OPENED". Are we in violation if a loan is scheduled to close on a Monday and the borrower did not “OPEN” the email until the 2nd business day (Thursday) prior to closing – even though we have evidence to show “ARRIVAL” of our CD on or before the 3rd business day prior to closing?
TRID Rule & Line of Credit Secured by Property
12/01/2019
Does a Line of Credit, secured by both a commercial property and a vacant residential property, apply to the TRID rule. The primary purpose of the loan is for business purposes.
