03/03/2008
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?
12/17/2007
What is required in a large bank CRA public file?
08/31/2007
04/09/2007
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?
08/28/2006
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?
08/07/2006
How far in advance is a HUD statement supposed to be presented to the buyer and/or seller before closing?
06/26/2006
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?
05/15/2006
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.
04/10/2006
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?
01/30/2006
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?