Vendor Guru Q&A - Lending

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Latest Lending - Reg. Z Topics

Home Equity Rate Special Disclosure Details

12/08/2019

Can we remove some of the details in a home equity rate special disclosure for billboard advertising and replace with a toll free number?

TRID Rule & Line of Credit Secured by Property

12/01/2019

Does a Line of Credit, secured by both a commercial property and a vacant residential property, apply to the TRID rule. The primary purpose of the loan is for business purposes.

Change to Loan One Day Before Initial Closing

12/01/2019

If you have changes to a loan product or loan amount, etc. one day prior to the initial closing disclosure being issued, can you use the initial CD to disclose the changes or do you have to reissue the loan estimate and restart the clock, or is there another solution?

Bank Required to Pay Interest on Escrowed Funds?

11/24/2019

Are there any regulatory requirements that a bank must pay interest on escrowed funds? This would be borrowers funds held for construction not tax and insurances.

Modification Fees on Construction-perm Loans

11/24/2019

I have a question regarding modification fees on our construction-perm loans. If additional fees are incurred at modification (Appraisal fee, recording fees, title fees, etc.) and were not disclosed on the loan estimate or closing disclosure, are we able to collect and charge them or would this be a TRID tolerance issue?

Right of Rescission Rule Interpretation

11/17/2019

I need some help with the right of rescission rule interpretation. On a refi loan, if the borrowers receive all TRID disclosures on a Saturday but our offices are closed that day so their signatures would have to be made on Monday. My question is, when should the 3 day rescission period begin? On Monday- Wednesday ( based on disclosures received on Saturday) or Tuesday-Thursday ( based on the effective signing date of Monday)? Reg Z states: 1026. 15(a)(3) i. The period within which the consumer may exercise the right to rescind runs for 3 business days from the last of 3 events: A. The occurrence that gives rise to the right of rescission. B. Delivery of all material disclosures that are relevant to the plan. C. Delivery to the consumer of the required rescission notice.

Code 3 on HMDA LAR Report (HOEPA)

11/03/2019

As to a loans HOEPA status, are second homes and vacation homes considered not applicable for HOEPA which would make the status code 3 on the HMDA LAR report?

Initial Disclosures Before Underwriting?

10/13/2019

Are initial disclosures required to have the borrower(s) signatures prior to going to underwriting for initial review? I understand that the loan estimate and 1003 need signatures but what about the other initial disclosure documents i.e.: toolkit, counseling forms, servicing disclosure, AfBA, FACTA, Privacy, Patriot etc..

Escrow short year statements

10/06/2019

Doing annual statements is a real pain every month. What can we do to make these easier?

Max Fee for NSF Check Returned for CC Payment

09/22/2019

What is the maximum fee allowed for a NSF check which was returned for a credit card payment? And is there a maximum fee for late charges for credit cards?

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.

Land Trust Department & Retail Banking Documents

12/08/2019

Are there any regulations concerning a Land Trust Department having access to retail banking documents in an institution?

Monthly Report on New Loans Documentation

12/08/2019

During a review of new loans for the previous month, I found that a joint credit report (husband/wife) was pulled for a new loan that was made to just 1 of them (the wife). The previous loan was a joint loan and a joint credit report was used then How do I need to document this finding in my monthly reports? Along with some additional training for the loan officer, what other things should I be aware of and keep in mind?

Opening Acct. for Campaign Fund- Use SSN?

12/08/2019

In the state of Texas, when opening an account for a campaign fund, are we required to have a TIN or can we use a SSN?

Equal Housing Lender Logo on Business Card?

12/08/2019

Does a mortgage lender's business card require an Equal Housing Lender logo?

Deed of Trust Construction Materials/Flood

12/08/2019

We have an interim construction loan that the real estate is in flood zone AE. Our Deed of Trust lists the real estate and the construction materials including drapes. All of the construction materials listed are covered under the buildings flood insurance, however the drapes are not. The plans and specs for the construction does not list drapes. Do we have to require contents coverage just to cover the drapes since it is listed in the Deed of Trust?

Latest Lending - Reg. Z Topics

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