05/21/2017
95% LTV. Initial Loan Estimate was issued 2/27/17 with the monthly FHA MIP falling off the loan at year 12. This error was caught and a corrected LE was issued on 3/7/17 reflecting the monthly MIP continuing throughout the 30 year loan term. This was Loan Officer error and isn't a valid Change of Circumstance but how would you advise we proceed? How do we
solve this? (Do we owe the borrowers the difference - that would be 18 years at $90 per month = $19,440!)
05/14/2017
Parents pass away and leave their home to their 3 children. Property went through probate. New deed was drawn up in 3 children's names. Said deed was never filed or recorded. One sibling wishes to Refi / Cash Out on the property and use the funds to buy out the other 2 siblings. Because the deed was never filed in the 3 siblings names, is this a purchase or a Refi transaction?
05/07/2017
Can an electronic document system streamline commercial real estate management?
05/07/2017
If there is a missing e-mail or no note of who a fee is being paid to, do we need to reissue the CD? According to the commentary on CFPB website the question was asked: Are creditors required to provide corrected Closing Disclosures if terms or costs change after consummation? (§1026.19(f)(2)(iii)) Yes, in some circumstances. Creditors must provide a corrected Closing
Disclosure if an event in connection with the settlement occurs during the 30-calendar-day period after consummation that causes the Closing Disclosure to become inaccurate and results in a change to an amount paid by the consumer from what was previously disclosed. Creditors also must provide a revised Closing Disclosure to correct non-numerical clerical errors and
document refunds for tolerance violations no later than 60 calendar days after consummation. (§ 1026.19(f)(2)(iv)-(v)). The commentary goes on to define the difference between clerical and non-clerical. However, missing who a fee goes to, does not affect timing, delivery or other requirements in 1026.19 (e) or (f) nor is it a tolerance violation. My thought is this does not fall into the parameter of "Yes, in some circumstances". So, do we reissue? or as one examiner stated write a letter explaining. That is no where to be found in the regulation either.
05/07/2017
We have been told that at loan origination the map and community number must match what is on the flood policy. Is this a FEMA requirement? Hartford Flood told me they are now having to pull updates at renewal time too so typically there will always be differences depending on what company you use.
05/07/2017
I am on the LaserPro documentation system and located in PA .. we recently started to get a pre payment critical warning in regards to prepayment penalties not being able to be charged on a Commercial Loan secured by a 1-2 residential unit property. Is this true?
04/16/2017
If you receive an application on 3-20-17 and the loan app. is applicable to TRID, do you have to do the LE if you decline within 3 days.
04/02/2017
A borrower is purchasing a new home. They wish to use temporary financing of a short term interest only loan secured by the old home, to purchase the new home, until the old home is sold and the loan is paid off.Is this a transaction subject to a right to rescind?
03/26/2017
When a borrower is deceased, family members continue to make payment and the account has an escrow account:
1. Is the bank still obligated to continue paying taxes and insurance from the escrow account?
2. If the loan has PMI does the company need to be notified?
If the loan does not have an escrow account:
1. If the loan payments are still being paid by a family member and the insurance is being paid but left in the deceased person's name, what avenue should the bank take?
03/26/2017
With the release of Fannie Mae's Day 1 Certainty, we are looking into allowing Property Inspection Waivers. If we exercise this option and the loan amount is over $250,000, can we prepare a written valuation to be compliant with ECOA or do we have to order a full appraisal since it is greater than $250,000? This would be in the State of Wyoming.