02/19/2017
When 1026.2 defines the six pieces of information that makes a complete application (and therefore starts the clock on the 30 day loan decision time frame), specifically the applicants income - are they referring to the income notated on the application only? Lenders are wanting to know if substantiating documentation of income is considered part of the application. I can't find anything concrete in the Regs saying that "income" is defined by what is on the application only.
02/19/2017
Where can I find a HOEPA Worksheet?
02/12/2017
I'm the internal auditor and reviewing compliance with SAFE Act and Reg Z for including unique identifier on loan documents. We originate our reverse mortgages through two investors. The documents are produced through the investor website. Does the NMLS # have to be on the GFE? I'm not seeing it on the GFE for either of our investors. What disclosure documents exactly is it required? (they have on the note, mortgage, application)
02/12/2017
Is the concept of “redlining” still an issue in 2017?
02/12/2017
If I am doing an apartment loan and the buildings consist of one 4 unit building and an 8 unit building, do I need to send an Appraisal Notice within 3 days?
02/05/2017
May a lender delay the processing of a home loan application because an applicant is on maternity/paternity leave?
02/05/2017
I have a question about a Closing Disclosure and the Disbursement Date on a no rescission loan with payoffs requiring funds from borrower received on the next day. Would we disclose the Disbursement Date on the CD as the same day as the closing date or the date we receive the borrower's funds and the actual funds are disbursed?
02/05/2017
I have a question about a Closing Disclosure and the Disbursement Date on a no rescission loan with payoffs requiring funds from borrower received on the next day. Would we disclose the Disbursement Date on the CD as the same day as the closing date or the date we receive the borrower's funds and the actual funds are disbursed?
01/29/2017
We made a loan in 2011 to a customer to purchase a property. The property had a residence and a commercial mechanics
garage with living quarters in it. At the time he bought this, he rented the house to his aunt and lived in the garage when he was in Missouri. He didn't reside here full time at that point. So we did this loan on our commercial side. We just found out his aunt has passed and he has been living full time in Mo. in the house. So knowing this, due to HOEPA or HPML etc ,are we required to move it to consumer side? Also where can I get further training on HOEPA and HMPL please?
01/22/2017
I read that the CFPB staff said that under “Other Costs” on page two of the Closing Disclosure, general lender credits not associated with any particular item must be listed at the bottom of the page as a negative number. The lender credit must be listed along with a narrative description if any refund is being provided by the creditor pursuant to the good faith analysis of charges. Notably, the CFPB staff said that lender credits associated with specific closing costs must be disclosed as paid by others and have an “L” for lender designation. This makes it seem like we would put the increase in appraisal cost on line 1 under Other costs. “variation due to an increase of appraisal cost above legal limit to ABC Appraisal” and put it as a cost paid by others column (L) $xxx UNLESS there is more than 1 item out of tolerance. Is this correct.