What rate is used to calculate the interest rate on a loan that is secured by a Certificate of Deposit account? The interest rate on the Certificate of Deposit or the APY on the Certificate of Deposit?
HMDA says a Home Purchase loan is any loan secured by and made for the purpose of purchasing a dwelling. I need clarification: If my commercial borrower wants to refinance his residential property to use the equity to-in his words-buy property in the future. Is this statement enough to make this a HMDA reportable loan for the reason Purchase?
When a Commercial Department is presented with an opportunity to provide a term sheet for a commercial loan - prior to receiving a loan application - is this request to be considered a loan application? Does HMDA reportable issue apply if the bank never received a loan application and there is no loan decision?
We are a small bank that does very little lending that requires a UCC filing. However, we have a request to finance a business that has inventory and A/R. I remember (from long ago seminars) a blanket statement that is noted in the UCC as well as specific asset description. What is this statement? What do I need to state on the UCC other than the specifics of the assets?
We make loans on manufactured homes, where the borrowers lease the land on which the home rests. We do escrow if the loan qualifies as an HPML. But do we have to also send out an Initial Escrow Account Disclosure Statement? 1026.35(b)(3) makes no mention of the statement. There is a reference in 1026.35((b)(3)(i)(2)of the Commentary, mentioning RESPA and the administration of escrow accounts, yet RESPA doesn't apply to these types of manufactured home loans. What to do?
On home equity lines of credit, how far in advance of payments must the billing statements be sent? If a bank chooses to make a change in the number of days must the customer be notified, and if so, how far in advance?
What is the effect of using an old form of Truth in Lending Disclosure Statement in a mortgage loan?
Is a HELOC that is not tied to a credit card or overdraft account, that is a fixed rate with fixed monthly payments required to have a periodic statement monthly?
The December 19, 2011 BankersOnline Weekly Banker Briefing contained an article under the lending section titled, "Requesting Tax Returns at Time of Application." I believe the answer given was incorrect. The BOL Guru stated that you can not "ask for verification documents until after the GFE is delivered and the applicant has indicated they wish to continue." What the regulation actually states is that you cannot require, â€œas a condition for providing a GFE, that an applicant submit supplemental documentation to verify the information provided on the application.â€ Is this correct?
Sec 1024.21(b) of RESPA states: Servicing Disclosure Statement; Requirements. (1) At the time an application for a mortgage servicing loan is submitted, or within 3 business days after submission of the application, the lender, mortgage broker who anticipates using table funding, or dealer who anticipates a first lien dealer loan shall provide to each person who applies for such a loan a Servicing Disclosure Statement. However, Sec 1024.21(c) states: Servicing Disclosure Statement; Delivery. If co-applicants indicate the same address on their application, one copy delivered to that address is sufficient. If different addresses are shown by co-applicants on the application, a copy must be delivered to each of the co-applicants. Could you please clarify the delivery requirements? It seems there are contradictory requirements between 1024.21(b) and (c). Is one copy sufficient (dependent on address) or does each applicant receive a copy?