Most Popular Lending Content
Signing One Form for All Disclosures
09/29/2003
For the upfront lending disclosures (e.g., Servicing Transfer Disclosure, ARM disclosures, etc.) for which the Bank is required to keep a customersigned acknowledgement of receipt, can the Bank substitute a "Disclosure Acknowledgement" form which the customer signs acknowledging receipt of all the disclosures? Or do the regulations require that the disclosures be individually signed?
What is HOEPA?
09/15/2003
What is HOEPA?
HUD's View of Mark-ups
09/15/2003
I noticed comment in Memorandum for update pages in a Mortgage Lending publication the following:"Several U.S. Circuit Courts of Appeal have disagreed with the Department of Housing and Urban Development (HUD) on whether mark-ups of third-party charges are violations of RESPA. For example, may a lender pay $15 to a credit reporting agency for a report and then charge the customer $30 for the report at closing and keep the $15 difference? HUD has said this would be a violation of the Real Estate Settlement Procedures Act (RESPA) and several courts have disagreed." Do you have any information concerning these court findings? Can this be done with this 3rd party charge or any others? Example; Could we charge for "payment coupon books" related to a mortgage loan payment?
Fair Lending, CRA, and Targeted Marketing
09/15/2003
If we were to target say a hospital and offer aspecial program to all employees (such as free checking, a special CD rate, a special mortgage interest rate, etc., toqualified applicants) would there be any repercussions as faras fair lending or any other compliance issues?
SSCRA Applicable to Enlistees?
09/15/2003
With respect to the Soldiers and Sailors Civil Relief Act (SSCRA), I understand debts incurred prior to entry into the military are subject to the 6% interest rate cap. Does it matter whether or not the military member voluntarily enlisted in the military? I thought the SSCRA would apply only if someone was drafted into the military.