06/02/2014
Our appraisal operations team uses a software platform and appraisal management companies to handle our appraisal pipeline. How do the CFPB and OCC view third-party service providers like this? What's our liability?
06/02/2014
Our appraisal operations team uses a software platform and appraisal management companies to handle our appraisal pipeline. How do the CFPB and OCC view third-party service providers like this? What's our liability?
05/19/2014
How do the new Third-Party Oversight requirements affect appraisal operations?
03/10/2014
I know that SCRA applies to all installment loans (i.e. not just mortgages, but auto loans as well), but I am wondering about the past due notices.
The model form/language is a HUD form (HUD-92070) that I understand should be sent with all past due mortgage notices, but what about other installment contracts?
Are we required to send it with all past due notices regardless of type of loan? Regardless of consumer vs. commercial?
05/20/2013
A director of a bank has a related interest. An employee of the related interest guarantees a loan for an entity that will provide services for the related interest. In addition, the related interest deducts the loan payments from the service providers check and sends it to the bank. The loan would not have been made without the guarantee of the related interest's employee. Would this loan be attributable to the Director through the Tangible Economic Benefit Rule of Reg O.
12/10/2012
If no list of providers was provided with the GFE, do the fees that were charged for the Lender and Owner Title Insurance have to be included on the 10% tolerance table on the HUD?
12/03/2012
Does RESPA require any charges in section line item 1300 -1310 to show on page 3 of the HUD as well? If the answer is yes, should it be under CHARGES THAT CAN CHANGE? I have noticed that some title co. do and some do not.
11/12/2012
Can a bank have a service provider list which does not list title companies and just put all title company fees in the charges that in total cannot increase more than 10 % column? If I am reading the RESPA Q & A correctly, if you do not provide a list the fees would be subject to the 10 % tolerance.
01/16/2012
I am processing a mortgage loan and the borrower is using a title company that is not on our service provider list. Our attorney will review the documents and has a review fee for that. Is this a finance charge? Where on the HUD do I put that fee?
09/13/2010
With regard to the GFE tolerance, in our area we only have one title company per county, so there is really no choice for the borrower. Could we include that in the Unlimited Tolerance level?