Vendor Guru Q&A - Lending

Latest Lending - Reg. Z Topics

Transfer Escrow on LE and Closing Disclosure

07/11/2021

We are refinancing an in-house loan, and want to transfer the escrow account. The customer has approved it, but how do we show it on the loan estimate and the closing disclosure?

Appraisal Waiver from a GSE (DU)

06/20/2021

When you get an appraisal waiver from a GSE (DU) do you put appraised value or estimated value on closing disclosure?

Appraisal Waiver from a GSE (DU)

06/20/2021

When you get an appraisal waiver from a GSE (DU) do you put appraised value or estimated value on closing disclosure?

Wage Garnishment or 401K Loan Expense (DTI)

05/30/2021

When evaluating a loan application, should a wage garnishment or 401K loan expense (each evident from a paystub) be included as a debt and calculated into the overall debt ratio (DTI)?

Language for "Required Deposit" Reg Z/Collateral

04/18/2021

We made a closed end loan secured by a vehicle and a CD. The disclosure statement is missing language pertaining to the "required deposit". Where in Reg Z can I find the information stating that both collateral items need to be listed on the disclosure statement if they truly do need to be listed?

Increasing Construction Only Loan-Disclosure

04/18/2021

I have a personal construction only loan that we are increasing. How do I disclose the fees that are associated with the increase? Can the bank charge a processing fee? The rate and maturity date are not changing.

HELOC Renewal with Outstanding Balance

04/16/2021

We have a HELOC up for renewal. The borrower has now moved and the home used is not his primary residence. He is currently renting out the property used for the HELOC. What are our options since there is still an outstanding balance?

Estimated Value on Loan estimate for Construction

03/21/2021

If I used an estimated value on a loan estimate for a construction loan where the customer already owns the land and no appraisal or valuation has been completed, will I use that same estimated value on the closing disclosure or can it be updated to the appraised value?

TRID Loans and Required Rate Cap

03/14/2021

All of our TRID loans are on a variable rate that changes monthly. I thought the required rate cap was an increase or decrease of 2% each time it changes. Now I cannot find any documentation regarding this issue. I know we have to disclose the ceiling but is the adjustment under our discretion?

Loan Estimate not Sent to Borrower

03/07/2021

intent to proceed prohibits charging fees other than for credit report before the Loan Estimate is provided and the applicant's intent to proceed has been confirmed and documented. If due to a technical issue which we discovered post closing the Loan Estimate was never sent to the borrower, is the lender obligated to refund all closing fees based on the Intent to proceed rule?

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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.

Pulling a Tri-credit Report for Fraud Victim

07/25/2021

We have a customer that is a victim of fraud. The customer called several different credit reporting agencies to get information and received several different answers regarding credit information. The customer wants us to pull a tri-credit report for them. Would this be a permissible purpose to pull the credit report?

Assessment Area Map for CRA Public File

07/25/2021

How does a bank best create an assessment area map and map of their county showing branch locations and census tracts for its CRA public file?

Collateral Address- Real Estate Secured (TRID)

07/18/2021

When populating the collateral address for consumer closed-end, real estate secured loans (TRID), is there an industry best standard for WHERE we obtain this address from? I know that it must always include the zip code, and a location (if an address via US Postal Service is not available), but I'm curious if there is an unspoken standard of what document this is best obtained from, such as the counties property record card, the written evaluation provided to us from a certified appraiser, borrower attested to, etc.

Call Report Code 1A2

07/18/2021

Our bank is currently scrubbing our loans in Call Report Code 1A2 - Other construction loans and all land development and other land loans. The following are questions to decide whether some loans are in the right bucket: - What classifies as farmland vs raw land? - Are loans secured by timber tracts considered farmland? - What call report code do trailer parks belong in? - Are they considered "other" land and belong in 1A2 or can it be classified as a 1E2 since it is an income producing property?

Disclosure Exceptions

07/18/2021

How can a bank track disclosure exceptions?

Latest Lending - Reg. Z Topics

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