Vendor Guru Q&A - Lending

Latest Lending - Reg. Z Topics

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?

Differences between MAPR and APR

03/07/2021

What is a MAPR?

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?

Eligibility for SCRA rate cap

02/28/2021

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

Debt-to-income ratio

02/21/2021

Does the General QM still require a 43% debt-to-income ratio.

Prepayment Penalties

02/14/2021

Do the revised rules restrict prepayment penalties?

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.

Document Imaging Technician

05/16/2021

What does a document imaging technician do?

Compliance aid

05/16/2021

It is my understanding that we must accept private flood insurance only if it contains the Compliance Aid statement. Correct?

Relocated Branch-CRA Public File as Closed?

05/16/2021

We relocated a branch. Based on the distance between both branches it was considered a relocation and not "closed." The question is, that if we must include that relocated branch in our CRA Public File as a closed branch?

E-SIGN when paper is still used

05/16/2021

If we are still delivering disclosures and statements in paper form, do we have to be concerned with E-SIGN or UETA?

Advertising Rate Sheet-"Limited Time Offer"

05/09/2021

We are creating a rate sheet to be used by local Realtors. It will provide the current rates for several types of loan products. Under our in-house loan category, Marketing would like to list "Limited Time Offer" as one of the bullet points. I recommended they provide an expiration date. Marketing wants to show that as follows - "Limited Time Offer. May Expire Without Notice." Since UDAAP is governed by perception of the reader what are your thoughts, I am still leaning toward a hard expiration date. What is required, or commonly done?

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