Vendor Guru Q&A - Lending

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Latest Lending - Reg. Z Topics

Getting Escrow Statements in Sync

10/14/2018

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

Right of rescission Apply to Early Occupancy?

10/07/2018

We have a customer that has occupied a residence that they are purchasing, and they do not have another residence. Does the right of rescission apply to early occupancy in a purchase transaction? We have gone round and round with differing opinions.

Test Consumer Real Estate Modification for HPML?

10/07/2018

Do we have to test a consumer real estate loan modification for HPML? The modification is occurring before the maturity date.

Verifying Closing Disclosure APR (Reg Z)

10/07/2018

How can we verify a Closing Disclosure APR for an adjustable rate consumer purpose loan that is secured by residential real estate? The terms in question are a 30 year mortgage with a 10/1 ARM.

Settlement Agent & File# on Closing Disclosure

09/30/2018

The closing Information box on our disclosure has "Settlement Agent & File#." If the lender is the settlement agent, (for a refinance) are they listed as the agent and the file number or can it be the loan number used?

Convert from Fixed Rate to Variable Rate?

09/30/2018

1) If we are modifying a consumer land only real estate loan, can we convert from a fixed rate to a variable rate without providing disclosures? The term of the modification period is 6 months. 2) Can we originate a consumer purpose real estate loan with a variable interest rate and a term of less than 12 months, such as for construction, without providing a CHARM booklet and ARM disclosures?

Charging Fees for Credit Reports

09/23/2018

We are looking at charging fees for credit reports. We have never done this. How do we do this correctly? We are looking for any recommendations or guidance you can offer.

"Life of Loan" Fee for Real Estate Tax Check

09/23/2018

Our state pays real estate taxes semi-annually. Can we charge a "life of loan" fee on consumer real estate loans for performing a real estate tax check? If we can charge such a fee, must it be incorporated into the loan origination fee (which we currently do not charge) or can it be a separate line item? If a separate line item, where does it get placed on the LE/CD?

Modifying Home Mortgage-Principal Reduction

09/23/2018

What are the rules for modifying a home mortgage loan to only lower a payment because the borrower made a significant principal reduction? He is not in foreclosure. Before TRID, we did modifications all of the time. Can you still do that? The rate and terms will stay the same.

Bona Fide Discount Points On 1st Mortgage

09/16/2018

Our customer wants to pay down the rate as much as possible on investment property. Is there a limit to how much a borrower can pay in bona fide discount points on a first mortgage?

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.

Loan Created in Signers Name-Company Debt

10/14/2018

A customer is signing for a company and owns 25% of the company, if a loan is created in the signers name would the companies debt need to be included in aggregate debt?

HMDA GIR Mixed Use Properties

10/14/2018

We made a loan to a non-profit for the purpose of acquiring and renovating 10 different properties. Loan is construction - perm. Eight of the properties are residential and the other two properties are commercial. The majority of the square footage (about 72%) of the total square footage of all ten properties is commercial. The two commercial properties are strictly commercial (not mixed use). The commercial properties comprise about 39% of the net collateral value, although the majority of the property values are lender's valuations, and not actual appraisals. I've looked through the HMDA GIR and do not see where this situation is addressed, unless I've overlooked it. The closest situation I could find addressed mixed use properties. In those situations, it stated it was at the lender's discretion, citing use of square footage or value. So I have square footage leaning to commercial (exempt) and value to residential (reportable). Would this be HMDA reportable?

Home Equity Loan: Improvement or Cash Out Refi?

10/14/2018

We are brand new to HMDA due to purchasing a branch in an MSA. We will start inputting in 2019. Our question is, if we have a home equity loan (we do not do LOC'S on home loans), it is to refinance existing mortgage and other funds are used for improvements to the property. Would that be a refi, home improvement or cash out refi?

Closed-End Threshold Test: Count Purchased Loans?

10/14/2018

Do we count purchased loans for the closed-end threshold test to determine if we are a small filer under HMDA? 1003.3(c)(4) states that the purchase of an interest in a pool of loans is an exempted transaction under HMDA, however I do not think that this includes mortgage loans purchased as a pool of loans. Thank you!

Getting Escrow Statements in Sync

10/14/2018

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

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