10/14/2002
10/07/2002
Our bank is introducing a new Home Equity Line of Credit loan service. We are considering mortgage lending protection insurance for each line, and wish to pass the premium on to the borrower/s. This would benefit the borrower/s as title policies or certificates would not be required. How should this cost be disclosed under Reg. Z and RESPA?
10/07/2002
I have a RESPA / Reg Z question that I am hoping Lucy Griffin can help me with. In some cases, a lender will waive or reduce a fee on a RESPA-related loan. When this is disclosed on the GFE and HUD-1 or HUD-1A they will list the full fee and then insert a lender credit on one of the empty lines in Section L on the form(s). Sometimes they determine up front that they will waive or reduce a fee, but they still list the full fee with the lender credit as a separate line item. Sometimes the fees they decide to reduce or waive are prepaids (for example points). The APR is calculated using the full fee in the amount financed calculation. Is there a problem with recording fees this way - either with RESPA or Reg Z? Based on Q12 in OCC's AL 2000-5, it seems that this would work basically like a coupon and would be okay, although it is disclosed in Section L rather than Section J (I'm not sure why they recommend Section J since there isn't one on a HUD-1A).
10/01/2002
Bankers tend to be peaceable folk. They mind their business, and the financial business of others, day after day.
09/16/2002
We have a home equity loan that is being used to purchase a new home. Does this fall under RESPA.
09/16/2002
What disclosures are required for a bridge loan to purchase a residence?
09/02/2002
We have always made it a practice to give an initial TIL on our home-equity closed end loans, no matter the purpose of the loan. Some of our offices state that they have never given an initial TIL only the final at loan closing. Can you tell me the specifics of when an initial TIL must be given on closed-end home-equity loans? I believe we have chosen always to over disclose and give the initial disclosure, instead trying to have our lenders remember when it is required and when it is not.
09/02/2002
For a commercial real estate loan with 3 units: one retail store and two residential units with one being occupied by the owner/borrower. Loan underwriting is done per commercial loan standards. If the loan is for refinancing, is this loan subject to RESPA and Reg Z. If this loan is for purchasing the property, is it a residential mortgage transaction under Reg Z?
09/02/2002
Our bank is considering providing an employee benefit which would reduce the closing fees when they finance a new home purchase or refinance their existing first mortgage. In particular, we are questioning whether the bank can pay for the outside costs such as attorney costs for title search and title insurance, appraisal fees, and etc. (for employees only) without violating any regulations.
09/02/2002
Someone is getting a loan secured by his home to add a pool to his backyard. Do RESPA and the Right of Rescission apply?