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Separating the Appraisal and Evaluation Functions - Mary Beth Guard
09/27/2004
Separating the Appraisal and Evaluation Functions
Answer by Mary Beth Guard, BOL Guru
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HOEPA's Treasury Rate Calculation
09/20/2004
The FFIEC Guide to HMDA Reporting provides two clear examples of how to calculate the Treasury yield based on whether the interest rate was set prior to the 15th of the month or after the 15th of the month. On interest rates set prior to the 15th of the month you would use the Treasury yield for the prior month and on interest rates set after the 15th of the month you would use the Treasury yield from the same month as the lock. I would like to confirm that the Treasury yield used for HOEPA purposes (I realize the Treasury yield is triggered by the application for credit date and not the lock date) is calculated in the same manner. There seems to be some differing opinion in that no matter what date the application was taken, the Treasury Yield would be used from the previous month. Please clarify this for me.
Rescission, New Loan, New Lender
09/20/2004
Is right of rescission applicable on a transfer of lien from another lender on a customers primary residence?
BSA Training Requirements
09/20/2004
What is considered adequate training under the Bank Secrecy Act for bank employees? Might this vary based on their duties?
Combined Fees on a Mortgage Loan
09/20/2004
Can a bank combine fees to others, such as for title policies and appraisals, into one bank fee and show the breakout as POC items on the HUD settlement statement?