Would the modification of the interest rate on an existing first lien principal residence mortgage loan require escrow for the higher-priced loan regulation?
Under the new HPML regs (226.35), escrow of taxes and insurance is only required if you are "extending a loan". If we are doing a rate modification on an existing loan, HPML calculations do not apply. Is this correct?
In light of the new regs regarding HPMLs and balloon payments, may we do an ARM that is adjustable every three years, but balloon it in seven years? We have been doing three or five year balloons on our in house loans prior to the recent change, but we really don't want to be tied to any index longer than seven years.
We have a mortgage loan in which a son is assuming the deed and mortgage loan from elderly mother and father with original terms of note. Are new disclosures required? If so, which ones? Does ROR apply?
A customer comes in to the bank to combine loans, one being a consumer loan and the other being a commercial loan. This seems to cause confusion among the lenders and processors. The method that has always been used is the loan that has the most remaining balance on it prevails. Is this to be considered a consumer loan or a commercial loan? Is there a set of state regs that should be a deciding factor here?
Do we need to provide insurance disclosures to a customer who purchased credit life A/H insurance on a loan with a business related purpose?
Are there any Regs that address verbal complaints? I have procedures for written complaints for CRA, but I am wondering about verbal complaints for any topic. Should I document a verbal complaint and retain the same way I do a written one?
How can we determine whether or not an individual is applying for a loan as a consumer or for business purposes? There is some ambiguity when it comes to investments. Are there any resources to help me with this?
When relying on a previous flood certification on a loan that has been renewed, are financial institutions required to give the notice to borrower when the property is located in a flood zone? (Keep in mind we gave and retained a copy of the initial notice in the file.)
I understand that you are not allowed to add outstanding interest to the principle amount of the loan on a refinance, but I can't find the Regs to support it. Can you tell me where they are?