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..
10/06/2019
Doing annual statements is a real pain every month. What can we do to make these easier?
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?
09/22/2019
When disclosing the payoff of an existing lien on the collateral property, should the amount listed on page 3 of the Closing Disclosure just show the
principal balance, or should it show the principal balance, plus the interest due?
I do not believe the reg goes into detail on what the amounts listed should be. My thought is we would need to list the amount that would fully pay off
that existing lien (principal, interest, late charges, etc. ). There have been discussions about not capitalizing off interest, but as long as we are not financing the
interest due into the new loan amount, I do not see how we would be capitalizing off previous interest.
In addition, if we list the full payoff amount, would we need to list just one payoff amount, or would we need to list
separate lines for principal, interest and late charges on the Closing Disclosure? I believe either way would be okay, but my thoughts are we would just need to list one line item with the full amount.
09/22/2019
We had a customer ask to start a voluntary escrow account on an existing loan. Do we need a new agreement?
09/15/2019
While auditing a mobile home loan I saw escrow statements. Isn’t this unnecessary since RESPA doesn’t apply when we don’t have real estate as our loan collateral?
09/01/2019
Reg Z covers individual consumer use for credit cards plus a few sections which are for business use, one of which is for unauthorized use if the
business has been issued 10 or more cards. What is the rule and/or regulatory expectation on how to handle legitimate billing error claims
(i.e., charged the wrong amount) from business card accounts? And, are there common business practices used in this scenario such as something
parallel to the individual consumer rule in TILA, 1026.13?
09/01/2019
We include the Equal Housing Lender logo in all our home loan ads. Are we also required to include the “Equal Opportunity Lender” logo?
08/25/2019
Can a lender purposely not get one of the six TRID items to avoid getting an application in order to delay the loan estimate delivery date?
08/25/2019
If we have a rate sheet that we give to real estate agents and our loan originators, but we know the true use will be for them to hand it to consumers or post it where consumers can readily access it, wouldn't we need to have the APR on it?
