Are initial PMI disclosures required on non-owner occupied purchase transactions?
Do I have to re-disclose to the borrower if the appraisal came back lower than expected and now has to have PMI on loan? I did not disclose with PMI.
Currently, during loan closing our Originations Dept only collects 2 months cushion and 1 month of P & I. Example: loan Closed in April and first P & I and T & I payment due 6/1. PMI company wants April and May PMI paid upfront. When I collect customer's payment in June that is for the June PMI Premium we get billed for around June 25th and must be paid by end of July to PMI Company because it's in arrears. Origination says they can't collect 2 months cushion and 2 months needed upfront because it's against the law (this coming from their ORIG System software update that occurred around 2006). It makes the customer short and during escrow analysis their payment goes up because it's missing. What are we doing wrong upfront? Can they really collect this and put it on POC Line? Before that software update in 2006, they collected 4 months now they only collect 3.
When including PMI insurance based on a monthly premium in the finance charge, how many months of the premium do you include as part of the finance charge?
Truth in Lending Tolerance for APR is typically .125%. I have mixed information regarding this tolerance for ARMS. What is the tolerance and where is it found in the Reg?
What are the consequences if we incorrectly quote the monthly PMI premium on the GFE? For example, we quote $50 per month, but the actual premium is $70.00 per month. Since this is not a valid reason to redisclose, would we need to pay the difference on behalf of the customer each month?
Is it a requirement to give a customer an amortization schedule if there is no mortgage insurance on the loan?
Do you have to include the escrow portion of the payment on the TIL for Reg. Z purposes? If an escrow payment increases during the life of an HPML, do we need to re-verify income based on the new payments?
We require that our members have an escrow account to pay their real estate taxes, homeowners insurance and PMI bills. When a member pays off his first mortgage, are we allowed to deduct the escrow balance from the payoff amount or do we have to refund the balance of the escrow account to the member? We have attended compliance seminars that advise us to refund the balance to the member however, our system is set up to deduct the escrow balance from the payoff amount.
When doing a loan with PMI, are we required to send out an amortization schedule with the GFE at the loan closing? Are we then required to keep a copy as proof of this in the loan file?