Regarding (possible) ARM loan disclosures and terms, we effectively give employees a lower rate on their loan while they are employed here. What we do is disclose the fixed contract rate and they pay those scheduled payments. The system however, is programmed with the lower discounted employee rate and the loan just prepays and when paid long enough, pays off early. If the borrower leaves our bank, we remove the discount from the system and revert to the contractual rate. The payment never changes except for the final payment which may then be less than scheduled. Would this be considered an adjustable rate mortgage? Is this an acceptable way to handle employee loans?
If the borrower receives funds as the rep payee for his disabled brothers, can that money be counted as income for the borrower when completing underwriting?
We have an existing construction loan that we would like to increase. Will this have to follow TRID rules or can we do a modification to increase the loan amount, charge a 1% loan fee on the new proceeds, add filing fees, title fees and any other fees that may be associated with the modification?
Can an individual loan accommodation for a personal, family or household purpose to an existing borrower with other business loans be considered non-consumer?
We have a purchase mortgage application that was approved with all underwriting conditions met. In review of the title run it was discovered the seller could not convey a clear title to the property. We did send the borrower a Notice of Action for Incomplete Application giving 10 days for clear title to be received. For HMDA purposes would the Action Taken be Approved Not Accepted or Denial?