We have loans in the Special Flood Hazard Area that were made prior to our becoming a participating county. Now that we do participate, do we need to require flood insurance or may we wait until one of the triggering events, i.e. renewal, extension, etc?
We currently have a first money purchase mortgage that matured in September, fixed rate, interest payments only. Now we are going to renew the note and extend for another year. What will change on the note will be P and I payments with amortization of twenty-five years, maturing in one year, no new money, rate stays the same. Is this loan now considered a new loan and what if any new disclosures do I need?
On a consumer loan that has a balloon payment, and you are re-doing the loan, but the rate changes, and dollar amount lower, is this a refinance or a renewal, secured by primary residence. The initial loan was one with balloon payments, so the application is a year old. Do we need a new one?
What are the reporting requirements for loans exceeding the Supervisory Loan to Value limits relative to the recent decline in real estate market values? Does a bank need to report a loan as a loan to value exception based upon the following scenarios? <ol><li>Loan to value was originally conforming at origination of loan; however, at renewal a new appraisal or evaluation reports a lower value which causes the LTV to be in excess of the Supervisory limits. Should the loan now be report as an exception or should loans only be reported if they are an exception at origination?<li>If during the term of a loan a new appraisal or evaluation is received that reports a lower value that would result in a LTV exception, should the loan be reported as an exception to the Supervisory limits?</ol>
HELOC Agreements reflect a floor of 3% APR. Due to economic conditions, management wishes to increase the floor to 5% APR and notify the consumers. I believe this is not permissible pursuant to Regulation Z 226.5b f (3), am I correct?
What is the time frame for recertifications? Are they required to be completed prior to the renewal, at the same time or within a certain time frame?
When renewing a note loan, is it necessary to collect the interest due at maturity or can it be added back to the principal balance of the loan?
How would we best handle a request for a wife be added to an open-end HELOC that is in the husband's name only? This transaction involves no new money and no extension of the original maturity date so should we prepare a renewal note and provide new disclosures?
If a balloon loan secured by a customer's primary residence is renewed are all RESPA disclosures required?
Under the SCRA, when reducing the rate to 6% on pre-service obligations is the 6% the interest rate or the APR?