The following notice is enclosed with annual escrow analysis statements which show a shortage to be repaid over a 12 month period: "Your escrow analysis statement for 2007 has a "shortage" that you can pay by September 14th. This remittance would reduce the new monthly escrow payment to a lesser amount, which would be the required projected monthly escrow payment. Please forward this statement along with your payment to the Loan Servicing Department". Is this a violation of RESPA?
What is required in a large bank CRA public file?
I have been researching a Reg B question in the BankersOnline InfoVault and cannot find this specific situation. We have a consumer home equity loan where a tax card was used as collateral valuation in lieu of an appraisal. County tax cards are a matter of public record. Should a Reg B notice have been provided to the customer to notify him of his rights to a copy of the appraisal in this case?
We are considering filing our UCC statements online, and the state charges a $2.00 surcharge for the service, which we would pass on to the borrower. I'm wondering if on a consumer transaction the $2.00 charge would need to be part of the APR?
How far in advance is a HUD statement supposed to be presented to the buyer and/or seller before closing?
When doing a consolidation loan for medical bills, is it acceptable for the bank to require statements of bills or is this violation of privacy?
When we provide disclosure statements which state that finance charges were included in the proceeds, and the customer decides to pay them up front, do we need to re-disclose? This is on a variable rate construction loan to build a primary residence.
What are the requirements for sending annual mortgage history statements to customers? We send the 1098 as required, but we are also sending a mortgage history statement to every account secured by real estate. Is this necessary?
On consumer loans, is it necessary to receive annual financial statements and tax returns after the loan has been funded? Is this a compliance issue, or a bank policy?