I have a question regarding modification fees on our construction-perm loans. If additional fees are incurred at modification (Appraisal fee, recording fees, title fees, etc.) and were not disclosed on the loan estimate or closing disclosure, are we able to collect and charge them or would this be a TRID tolerance issue?
For HMDA reporting purposes: An applicant's demographic information is obtained at time of application via an online application process and the data collected is the information input onto the HMDA LAR. But if the applicant changes the demographic info at consummation (at the title company) do we change the data on the LAR from the data collected at application to the data collected at consummation?
Are there any regulatory requirements that a bank must pay interest on escrowed funds? This would be borrowers funds held for construction not tax and insurances.
We are not examined by the CFPB. Should we be worried about Section 8 violations?
Are all transactions that are HMDA reportable counted toward the thresholds?