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.
The IRS 1098 reporting instructions do not address the ownership of the real property subject to a loan and are we required to report for commercial loans too? Assuming all the conditions are met for a commercial real estate loan (borrower is an individual, payer is an individual, and the interest paid is over $600), should we really ignore the ownership of the property? We have a case in which the real property is owned by an affiliate business entity which is an LLC.
If you have changes to a loan product or loan amount, etc. one day prior to the initial closing disclosure being issued, can you use the initial CD to disclose the changes or do you have to reissue the loan estimate and restart the clock, or is there another solution?
My compliance officer says we have an affiliated business arrangement with a title insurance company that is 20% owned by our holding company. I thought the rules kicked in with 25% ownership. Who’s right?
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.