We are in the process of developing a Jumbo HELOC product. There would be no fees associated with this product, but there is an annual fee of $90, interest-only payments and the balance would come due in 5 years. Considering the balance due in 5 years, would this product be subject to Ability To Repay?
Doing annual statements is a real pain every month. What can we do to make these easier?
We have made a loan to a builder to construct a spec home. Does ECOA apply? The same builder also has a contract build; does ECOA apply to that? We structured both of these as interim construction because both will be refinanced once the homes are complete. Neither will be our borrowers as these are investment properties.
What does the "stay" of the compliance date for the Payday Loan Rule do?
What’s the best way to switch from one imaging system to another?