Does a Line of Credit, secured by both a commercial property and a vacant residential property, apply to the TRID rule. The primary purpose of the loan is for business purposes.
The IRS 1098 reporting instructions do not address the ownership of the real property subject to a loan and are we required to report for commercial loans too? Assuming all the conditions are met for a commercial real estate loan (borrower is an individual, payer is an individual, and the interest paid is over $600), should we really ignore the ownership of the property? We have a case in which the real property is owned by an affiliate business entity which is an LLC.
I have a question regarding modification fees on our construction-perm loans. If additional fees are incurred at modification (Appraisal fee, recording fees, title fees, etc.) and were not disclosed on the loan estimate or closing disclosure, are we able to collect and charge them or would this be a TRID tolerance issue?
For HMDA reporting purposes: An applicant's demographic information is obtained at time of application via an online application process and the data collected is the information input onto the HMDA LAR. But if the applicant changes the demographic info at consummation (at the title company) do we change the data on the LAR from the data collected at application to the data collected at consummation?
Are there any regulatory requirements that a bank must pay interest on escrowed funds? This would be borrowers funds held for construction not tax and insurances.