11/18/2018
I am new to lending compliance and have an advertising question. My bank wants to advertise the following:
"Enjoy our special 20-year financing offer. Ask us for details."
I am of the opinion that "20 year financing" is a trigger term and therefore requires APR, down payment and repayment terms. My predecessor disagrees
because an interest rate is not quoted.
Along the same lines, if an advertisement says, "15 and 30 year fixed rate loans available" would we have to disclose rate and payment options for both
terms assuming this is a trigger term?
11/04/2018
When pest treatment is required and if the seller is responsible for that cost, does that still constitute redisclosure of loan estimate?
11/04/2018
Is there suggested text for a letter concerning an escrow overage?
11/04/2018
When escrow provided a Master Settlement statement with fees for us, the lender to disclose to our buyer on a purchase, they had transfer
taxes and owners title being paid by the seller. They have now sent out an amendment changing those 2 fees to be paid by the buyer because that is how
the contract was drawn up. Is this a valid change of circumstance? Or a tolerance violation?
11/04/2018
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?
10/28/2018
We are moving to offer higher rates and eliminate origination fees to include broker fees when a broker is involved. Instead we would pay the broker upfront, and hopefully collect that fee in interest over the next several years. Do we have to disclose the broker fee as a lender paid item POC, or do we eliminate it all together?
10/28/2018
Based on the TRID amendment effective 10/1/18, if a consumer decides to increase a loan amount after the initial loan estimate has been issued, is a revised LE required to comply with the new tolerance for Total of Payments disclosure?
10/28/2018
I have an investor that is wanting me to issue a final closing disclosure (CloD) with the sellers fees. This would be fine, but they are asking for it to be on my buyers closing disclosure. We normally issue a final CLoD for the buyer and get a CLoD from escrow for the seller. Is my investor correct in asking for the fees to be on my buyers CLoD (fees include Realtor commissions, Owners Title, Transfer Tax, Realtor processing fees, etc.)?
10/21/2018
We recently found a fee that was charged to a borrower and needs to be cured. The closing has already happened and we charged too much. Could you tell me the proper steps on how to cure a loan post consummation and where do we place the cured amount on the cd?
10/21/2018
We have a farmer who has all of his payments set up to pay annually when the crops are harvested. He is purchasing his primary residence. Can he have this set up on annual payments? I was thinking that all primary residence loans had to be set up on monthly payments?