Vendor Guru Q&A - Lending

Latest Lending - Reg. Z Topics

Correcting a Loan Estimate

03/19/2023

On the loan estimate, I input it as a balloon rather than installment which drastically increased the payment. Do I need to redisclose theis with a revised LE or do I make the correction in the closing disclosure?

Incentive for Loan Auto-Pay

03/12/2023

Instead of offering a preferred rate (discount) when auto-payments are set up for a loan, we want to offer instead a discount on doc fee charges. Is there any regulation/issue that would prohibit us from doing this?

Loan Purpose on 50/50 Loan

02/26/2023

Here is the loan scenario: We have a HELOC for $100,000. Collateral on the loan is rental property. The loan purpose is for home improvement. Our borrower stated that funds will be used as follows: - $50,000 to do home improvement on rental property, and - $50,000 will be used for home improvement on their primary residence. Would this HELOC be considered primarily for business or commercial purposes and why?

TRID Required Wait Times Confusion

02/26/2023

I have an auditor questioning the timing of the revised Loan Estimate and loan consummation. I informed auditor that the borrower was sent revised Loan Estimate four business days prior to consummation and that is in line with the regulation; and the 7 business days requirement references the initial Loan Estimate (not revisions) --- Am I understanding the regs correctly or not?

Retention of Credit Line Statements

02/19/2023

We finance furniture and household goods purchases and establish credit lines for customers. We have retained statements since inception in the late 1970's, These statements are for revolving, installment and net 30 commercial accounts. How long are we legally obligated to retain this documentation in our system? I thought it was 7 years, but in reading through Reg Z - Record Retention, it sounds like it may be 2 years after closure and a zero balance is reached. Is there a difference for charge off / bankruptcy accounts?

Why bother with a Seasoned QM?

02/12/2023

My Chief Credit Officer asked why we should bother with Seasoned QMs in a rising rate environment. I’m not sure what to tell him. Can you help?

I’m not in a rural / underserved area. Can I make a Small Creditor QM?

02/05/2023

To be a Small Creditor QM, must the loan be made in a rural or underserved area?

Rates are rising! How does this affect ATR / QM underwriting?

01/29/2023

With rates going up, we are seeing increasing demand for ARM loans or introductory rate loans. What do I need to know about them for QM or ATR underwriting?

What is an EGRRCPA QM and why should I care?

01/22/2023

What is an EGRRCPA QM and why should I care?

What is the difference between HPML, HPCT and HCML?

01/15/2023

I can’t keep it straight anymore. What is the difference between an HPML, and HPCT, and an HCML? Aren’t they all virtually the same thing?

Premium Content View All

Regulation Z Ability to Repay (ATR) Monthly Payment Underwriting Calculation Quick Reference Guide

Effective January 10, 2014, the Standard Ability-to-Repay (ATR) and Qualified Mortgage (QM) regulations require Creditors to determine a consumer’s ability-to-repay the covered transaction using th

CFPB Mortgage Servicing Tools

The CFPB updated its Small Entity Compliance Guide (Version 3.1) for the 2016 Mortgage Servicing Final Rule on March 29, 2018, to incorporate the changes made by the March 8, 2018 final amendments.

Re-perfecting a UCC Lien

03/26/2023

When a UCC is terminated, then the following year it is continued, then continued a second time, is that a valid perfection?

Loan policy exception

03/26/2023

What is a loan policy exception?

Treasury reclamations on decedents’ accounts

03/26/2023

If the money is not available in the deceased customer’s account and no estate account exists with the bank, is the bank still liable for reclamations from Treasury?

Notice at Closing of Required Insurance

03/26/2023

Is it required to have a separate "Agreement to Provide Insurance" form signed for non-real estate secured loans? We are in Tennessee and currently have a section in the Security Agreement that prints with the Note which states the borrower agrees to keep the property insured and if they fail to provide insurance, then the bank may place insurance on the property (Creditor-Placed Insurance Notice) and pass that cost to the borrower.

Unpaid Board Members and Reg O

03/19/2023

We have a board member who sits on the board of a condominium association, but does not receive any compensation to do so by the association. Would making a loan to the condominium association be considered a conflict of interest/Reg O violation? We are thinking not since they are serving on the condo association as a resident (condo owner) in the complex.

Latest Lending - Reg. Z Topics

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