What do other banks do about notice letters?
After watching an escrow webinar my bank decided to no longer add the 3% to the premium amount on the closing disclosure. Since the webinar, I have forgotten and did not properly document why. Can you please confirm or advise me on the initial escrow statement, per regulation, if we can add this? I recall it was created from the CPI Index. I understood this could be added at the annual escrow analysis, but NOT on the closing disclosure or Initial Escrow Statement/Disclosure. Is that right, or can we add the CPI index at the time of creating the escrow account?
If the bank charges PMI and doesn't have a PMI insurance company that it has to pay can the bank truly collect the PMI? For example, if the bank had loans that didn't sell on the secondary market, and the insurance gets cancelled, can the bank still collect for the PMI?
When it comes to auto loan rates, we have certain rate discounts that may apply based on an "Engagement Score" for each person. This is determined by our underwriting team and communicated to the dealer for the best rate available at the time the deal is happening so that the correct rate is listed on the contract. The problem is after 5pm when our underwriters go home, we are still getting deals since dealerships are open later. The next day we have a contract signed for the rate the customer qualified for but does not include any engagement score discount. My question is: After booking the loan at the rate listed on the contract, may we then adjust the rate down to include the engagement score discount the customer should have received without having to ask the member to sign anything? I assume we could adjust a rate like this so long as it benefits the customer and we document what we're doing and why, but I'm struggling to find a definitive answer in a Reg.
Are all TRID transactions subject to the right of rescission?