While auditing a mobile home loan I saw escrow statements. Isn’t this unnecessary since RESPA doesn’t apply when we don’t have real estate as our loan collateral?
We want to know if there is a vendor or website our bank can utilize to quickly retrieve public records online from various Secretary of State offices, tax cards & tax bills to pay escrowed taxes, retrieve recorded real estate docs i.e. recorded Warranty/Quitclaim Deeds, MTG-DOT and AOR's. The majority of states have their records available online but behind a paywall where you have to pay for each individual page of each document. There's 25+ of us between Lending, Legal, and Compliance that need access at our bank to these docs. In my previous banking career, we utilized a website called NETRONLINE.com with a paid subscription but it appears it is no longer available. Is there a substitute?
PMI Insurance, we are receiving contradictory views on how to complete the escrow block on the closing disclosure. What is your take on how the Closing Disclosure should be completed when the borrower is paying PMI and with no prepaid PMI?
We had a customer ask to start a voluntary escrow account on an existing loan. Do we need a new agreement?
Do you have to revise the issue date of the Final CD to match the CD date if nothing has changed from the Initial CD issue?
How is e-mail delivery for the disclosures considered as far as timing?
If we have a rate sheet that we give to real estate agents and our loan originators, but we know the true use will be for them to hand it to consumers or post it where consumers can readily access it, wouldn't we need to have the APR on it?
It is my understanding that we have 30 days to notify the customer of our loan decision when denying the request. My question is, does the letter date have to reflect the same date of denial? I had a loan officer deny a mortgage loan within three days of application to avoid early disclosure requirements, but then the application was re-activated and the lender made a second decision with a later date. This second decision date makes the denial notice reflect more than three days from the application date.
Has the CFPB provided sample forms for construction loans?
Our mortgage department is putting together a script for a generic radio ad promoting their department and our offering of home loans. I know the obvious requirement of FDIC and EHL being mentioned. However, I'm unable to find concrete support as to whether our bank's NMLS ID must also be included. I saw a comment in the forum stating that banks aren't required to include it but can't find regulatory guidance to support that. Can you offer me some wisdom or direct me to a resource? I'm in Texas, by the way. I've also searched for state specifications and came up empty.