Vendor Guru Q&A - Lending

Latest Lending - Refinancing Topics

HMDA Refi Conditions

07/17/2022

In order to be considered HMDA reportable as a refinance, does the loan have to payoff an existing loan to the same lender?

Terminology Use - Cash Out

06/05/2022

I used the term "cash out" for a purpose on a loan. Would this term be wrong if I am giving out new money?

Commercial Loan Modifications

05/15/2022

Do you need to modify or prepare a change in terms on a commercial loan when lowering the interest rate but not changing the maturity date? Can it just be done with a maintenance request?

Code for Automobile Loan Renewal

12/08/2019

How should an automobile loan originally used to purchase an auto be coded when the loan is renewed?

Converting Fixed Mortgage to ARM-Refi?

06/23/2019

Can a 30 year fixed mortgage be converted to a 5/1 ARM mortgage? What information needs to be provided to the consumer to have this done and can it be a modification or must it be a refinance?

Modifying Real Estate ARM Loan-Disclosures

02/03/2019

On a consumer real estate ARM loan, the loan just adjusted. The officer is requesting to modify the loan and change the index, margin, and adjustment period. The request is primarily due to competitive reasons. Can we change the index, margin, and adjustment period without having to do disclosures?

Modifying Home Mortgage-Principal Reduction

09/23/2018

What are the rules for modifying a home mortgage loan to only lower a payment because the borrower made a significant principal reduction? He is not in foreclosure. Before TRID, we did modifications all of the time. Can you still do that? The rate and terms will stay the same.

Loan to Pay Off Partners Per HUD- True Refinance?

06/24/2018

An entity is refinancing a loan .....the purpose of the loan is to provide funds to refinance the existing debt on a SFR. The proceeds are not being used to pay off another financial institution but to pay off the partners per the HUD. Is this a true refinance?

Finance Unpaid Interest Accrued- Renewal loan

02/11/2018

On a renewal loan (a loan that has matured that is already on the books),. can you finance the unpaid interest that has accrued on the loan you are renewing? What is the answer if you change the loan number and if you don't if there is a difference. I have received conflicting answers on this and would like to know if it is a violation if you roll the unpaid interest in on a note that you are renewing.

Modify ARM and Payment Increases-Refinance?

10/29/2017

If we are doing a modification for an ARM Loan and the payment increases, some of our staff believe this is a "refinance", some do not. Thoughts? If so, -What do we need to provide to the consumer? There would be no costs associated - just the new terms with the new (current rate)? It doesn't seem like a CD would be appropriate - If not - then we would use our normal modification agreement.

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Rescission Rules for Multi-Purpose Loan

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New HPML Rules Defined

12/04/2022

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?

When is a new flood policy required on a new loan?

12/04/2022

Does flood insurance need to be in effect the day before a loan closes or the day of is sufficient?

HMDA "Purpose" when paying a tax lien

12/04/2022

We have a HELOC that is going to pay off a tax lien on a dwelling. Should the purpose be reported as "Refinance" or "Other" for HMDA purposes?

Automated exception reports

12/04/2022

What are the potential benefits of automated exception reports?

Auditing Bank Sold Insurance

11/27/2022

We receive submitted applications from our website that are considered complete per TRID. Upon receiving the submitted application, we attempt to directly contact the applicants by phone or email regarding the application and items needed to make a loan decision. If we do not receive any contact from the applicant, what are the notification requirements? Should the app be considered incomplete and we send a Notice of Incompleteness and if there is still no response by a certain date, we can close the file? Also, what would the timing requirements be to send the notice and then to be able to close the file?

Latest Lending - Refinancing Topics

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