Vendor Guru Q&A - Lending

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Latest Lending - Reg. Z Topics

E-Sign Rules When Emailing CD (3 Days)

02/10/2019

Are we required to always follow the E-sign rules when emailing a CD to the borrower 3 days before closing? For instance if we deliver the CD by email (without following E-sign) and the borrower replies that they have received and read the CD, is that sufficient proof that the CD was delivered 3 days before closing? We do not require the borrowers to sign the CD.

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?

How to Tell if Loan is Cross Collateralized

01/27/2019

How can I tell if a loan is cross collateralized, what language shall I look for and in what document?

TRID-Release Fee to Consumer Mortgage Payoff?

01/27/2019

Are we allowed under TRID to add a release fee to a consumer mortgage payoff? The fee would be for recording the satisfaction of mortgage.

Reg Z Reviews that Include TRID 2 Amendments

01/06/2019

Since the CFPB's Reg Z Exam Procedures have not been updated (as of 12/11/18) to include the TRID 2 amendments effective 10/1/18, other than going through each section of the regulation, what do you suggest we use (in place of the Exam Procedures) as the 'next best thing' in doing Reg Z reviews that include the TRID 2 amendments?

"Sale Price" On LE/CD for Transaction w/Seller

01/06/2019

Asking this question for both current and future rules: On a construction-permanent loan application that has only one closing and one set of LE/CD disclosures for the transaction, what should the "sale price" be on the LE/CD with a transaction that involves a seller? Should it only be the amount of the purchase price or should the cost to construct be included with the purchase price? I'm leaning towards the purchase price only based on 1026.37(a)(7) but we've been adding in the construction costs for some time now without criticism...

Rate/Payment Change Disclosures Under Reg Z?

12/30/2018

We have a fixed rate residential mortgage loan borrower. We provided a loan modification of both the rate and payment for 5 years. After this period the rate will return to the higher original rate. Once the 5 year modification term is up, are we required to provide any rate/payment change disclosures under Reg Z?

Adding Co-Borrower After Closing Disclosure

12/30/2018

Can a co-borrower be added to a loan after a closing disclosure is issued?

Eligibility for SCRA rate cap

12/30/2018

A soldier’s mother called to tell us her son joined the Army. Do we have to reduce the loan rate that day?

Increasing HELOC-Send New Preliminary Docs?

12/23/2018

Do you have to send out new preliminary documents when increasing a Home Equity Line of Credit loan?

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.

RESPA- "Giving Out Three Lender Names"

02/10/2019

I am preparing education training for Realtors. My topic: "How to Work With Lenders." I want to address the age old response I hear from Realtors when asking for referrals. Often they will say, "we have to give out three lender names." I can't find anything under RESPA that requires this. Is this a part of Section 8 or another regulation? Briefly, what can a Realtor do that won't get the mortgage lender in trouble which may be beneficial to everyone?

Interest Amount Collected for Loan Extensions

02/10/2019

I am auditing loan extensions, and I am coming across several loans where the payment the customer makes after the extension is not bumping the next payment due date. I have figured out that this is due to our loan staff not collecting enough accrued interest. So the customer's payment went to interest, not bumping the due date. My question is : When granting an extension, what interest amount should be collected? What is currently accrued and owed at the time of the extension? or like my Bank is doing taking the per diem X the number of days extending? What is the best practice?

Complete Full Cash Flow? Ability to Repay Rules

02/10/2019

We currently have a consumer in the permanent financing phase of a construction/permanent loan. There was no guarantee we would provide the permanent financing at our bank. When construction was approved the borrower was considered self-employed. He owned two businesses and within the last year has sold a large portion of his businesses and now receives a salary as a manager, rather than an owner. Do we need to complete a full cash flow on this borrower, or could we use the current income received from his salary for ability to repay rules?

Home Improvement Loan- HPML and Escrow?

02/10/2019

I have a home improvement loan for 6 months. On the home improvement loan is it really considered a HPML and I should do Escrow?

Pre-submission HMDA Checkup

02/10/2019

Our financial institution is not a bank or credit union and is regulated by the state. We do not see a choice to enter our regulator on the HMDA LAR. What do we do?

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