Most Popular Lending Content
Required Changes
01/24/2021
Are we required to make changes in response to the new final rules?
Written Permission to Access Credit Reports Required
01/24/2021
Written Permission to Access Credit Reports Required
When a Servicemember Asks for More than SCRA Relief
01/24/2021
A soldier wants us to reduce the loan rate and allow three deferred payments to bring the account current. Are we required to do this?
HMDA: Third-party agent underwriting loans
01/17/2021
Our financial institution has engaged a third-party mortgage lender to process our applications, including underwriting, on our behalf. We report these on our HMDA LAR. Our examiners are questioning this and feel the third party should report because they made the credit decisions. What should we do?
Construction Perm Product & Upcoming TRID Rules
01/17/2021
I have recently learned about a rather unique construction perm product and have a question about it in regard to the new upcoming TRID rules. Here's how the product functions now. The loan is a one-time close, 30-year term, fully amortizing from the beginning. Only one LE/CD is issued. The rate is fixed at opening and does not change at all during the term. There is no interest-only period. At closing, the funds are put into an escrow/reserve account and disbursed to the borrower periodically over the construction period. At this time they do not charge any inspection fees but are considering changing their process to have the inspections conducted by a third party and charging for three inspections. If these fees are disclosed to be collected at consummation, what recourse is there if an event occurs that requires an additional inspection? Does the bank simply have to absorb that cost since this is a zero tolerance cost and the CD has already been issued and compared to the LE? If these fees are to be collected after consummation, disclosed on a separate addendum, and this event requiring the additional inspection occurs, can the bank simply collect the additional fee without violating the zero tolerance?
