07/31/2016
(Under ECOA) After we have a credit-only approval for an application, how long can the application remain active in our pipeline? For example, if we submit a credit-only file to an underwriter (without a property) and the file is conditionally approved (based on credit qualification only), and the applicant is looking for a home or waiting for a new construction to be finished, how long can we hold that app in our pipeline before getting scrutinized by an examiner (we are under the FRB)?
I’ve seen a range from 45 to 90 days – but obviously, we want as big of a window as possible before we have to action the loan … especially if the borrower is simply waiting for their property to be completed.
07/24/2016
After closing on a real estate, if the fee charged for an attorney or abstract is under what we cut the check for, do we need to issue a new closing disclosure to the customer? I understand they will receive the refund, but not sure on the CD part.
07/24/2016
Where does the Seller sign on the closing disclosure?
If I have a mortgage purchase transaction, does the closing disclosure issue date need to be dated 3 days before the other loan closing documents?
07/24/2016
We had a 30 year fixed loan modified to a 5 - year balloon due to collection issues. The balloon is now past due
and we want to do a workout/refi back to the original terms of the original 30 - year note. Would we have to disclose?
Our main concern is this is a workout/refi of an expired balloon modification..
07/17/2016
I have a question related to long backdating (or just backdating) for force placed insurance. I am not finding a lot of information regarding backdating polices other than the standard 45 days that is required when placing a policy that has lapsed or expired.
Does anyone know if there are current lawsuits concerning backdating a policy to an 'effective date' and charging the customer for that time even if nothing happened to their dwelling? For example, when we charge the customer on the 45th day of a new
policy, but it is back dated to when their policy expired or lapsed, is this seen as a UDAAP issue with consumers? In essence we are charging them for a policy when they did not have a claim, so I am unsure what recommendations I should make regarding backdating polices. And, there are no kickbacks, this is simply a backdating question and premiums for servicing. I hope this makes sense! I am having difficulty finding any litigation and/or trends regarding this. Any feedback is welcomed. I am familiar with the process of 1024.37 however am looking a little deeper into the effective dates of polices placed, hazard or flood. Also cannot find much on Fannie Mae or Freddi Mac.
07/10/2016
We are doing a construction permanent loan for a customer who already owns the land free and clear. Is a right to rescind required?
07/10/2016
I have a real estate loan that has past due county taxes.
When we disclose this on the loan estimate, should it be on taxes and other government fees or listed under other as past due taxes?
07/03/2016
A Trust owns a single family home which is currently rented. The owner of the Trust is deceased, so it is no longer an inter-vivos trust. A bank makes a loan to the Trust at a 14 year fixed rate, (5.99%) secured by the property. The Trustees are not personal signers, only the Trust is obligated. The loan to value is approximately 60%. Do TRID rules apply to this situation? Is a LE and/or CLoD required? What about ATR rules? The interest rate seems exorbitant.
07/03/2016
If you are extending the maturity date only on a consumer real estate loan or a lot loan would you be subject to providing customer with a Truth In Lending document/Reg Z? Thank you!
06/26/2016
Do we have to give an appraisal disclosure to a home builder for each dwelling that is being built or can we use a master disclosure to cover all dwellings being built in the housing development?