Would it be considered an issue if we “favor” the loan applications that are sent to us from one real estate agency over another if they just send us more of them?
Is it okay for us to share subscription services that the bank has access to with our mortgage service providers?
What is the big deal with a mortgage loan originator trying to increase their sales volume by promoting the realtors that they work with and that they know also do well? Doesn’t this ultimately help everyone in the bank to do better too?
Are Marketing Servicing Agreements or MSAs legal?
Is the any regulation that prohibits a credit union member from paying their mortgage ahead by a specific number of months?
The initial and locked Loan Estimate (LE) on an ARM loan was based off the WSJP index. When it was time to issue the initial Closing Disclosure (CD), the WSJP index had increased causing the APR on the CD to be about 1/2% higher than on the last LE. Should we adjust the index value on the CD to match the index value used on the LE to keep the APR within tolerance, or do we need to update the index value to the current value and redisclose the LE and then inssue an initial CD?
Are there alternatives to extensions are others using when dealing with construction-to-perm loans that are not finished my maturity?
We are considering the possibility of advancing any remaining proceeds available on the loan to a checking account, which would have a hold to prevent use outside of the original agreement, and starting P&I repayment rather than extending the loan. We would continue to draw those funds to complete construction, just from the checking account rather than the loan itself. Curious if there are any drawbacks or compliance issues with this method.
Are short term loans (loans that will not be satisfied and replaced with permanent financing; paid out in full instead) subject to HOEPA and HPML?
I see that temporary loans and bridge loans -12 months or less (loans that will be satisfied and replaced with permanent financing) are not subject to HPML.
I believe temporary and short term loans are subject to HOEPA though.
We want to offer finacial webinars in Spanish to consumers. These would include smart ways to purchase a vehicle or a home and we have many more topics in mind. Would we need to supply disclosures or other documents in the Spanish if we do this?
A UCC filing fee paid to a government entity to perfect a security interest in a consumer product must be listed in the Fed Box to avoid being a finance charge and included in the APR. Our filing fee is paid to a non-government third party vendor. Because of this third party involvement, our compliance department feels the fee should not be listed in the Fed Box. If all or a portion of filing fee we charge to the borrower will be paid to the government entity I feel that portion should be noted excluded from the finance charge and APR. Do you agree?