Under the new QM/ATR rules that take effect on Oct 1, 2022, when does a loan become HPML? Is it still based on the 1.5%-1st lien, 3.5%-2nd lien, or does it now go by the new thresholds in the price-based tiers, for instance, 1st lien is less than $68,908 has a 6.5% threshold between the APR & APOR?
Will section 1071 rules be covered in the program?
Are escrows required for commercial loans?
A soldier wants us to reduce the loan rate and allow three deferred payments to bring the account current. Are we required to do this?
Are we required to use a rate sheet for commercial loans?
The Military Lending Act does not specify if the Act applies to an open-ended Overdraft Protection line that is tied to a checking account or a closed-ended loan secured by the applicants’ deposit accounts such as a savings and/or certificate of deposit. Does the Rule apply to both consumer credit types?
Aren’t fair lending concerns limited to mortgage loans?
This is about HMDA reporting for Loan Purposes under 1003.4(a)(3)-6. I think I might am being too literal in my understanding of home purchase. A customer is getting a loan, using their primary residence as a collateral, making this a refinance. The cash out portion will be funding is to purchase another property as investment rental.
Our line of business is stating this would then be a home purchase because "Purchase" trumps refi. I do not agree. I feel that because they are using the refi loan as the source of funds it stays as a refi. If they were using the other property as collateral then I would agree. In that case it would be a home purchase because they are buying the collateral with the loan.
How should this be coded for HMDA?
If our borrower hasn’t requested SCRA protection and is past due on her mortgage, can we start foreclosure as we normally would?
I thought business purpose loans were exempt from HMDA reporting.