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?
I have a business account that is purchasing a vehicle for the business and I have been asked if there is any compliance issue titling the vehicle in the business name. I cannot find any information regarding this on the michigan.gov site or in my compliance information. Are you aware of any state or national issues here?
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?
If you have a Filing Fee (lien on title) and a UCC1 recording fee to the State, would both of these amounts be reflected in the Fed Box or just the Filing fee on the title?
As a lender (agent) in a syndication deal, what are the responsibilities of the agent bank with respect to Regulation B (ECOA) compliance specifically related to adverse action notice requirements?