Vendor Guru Q&A - Lending

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Latest Lending - TILA Topics

Commercial Customer Receive Reg. Z Statement?

03/12/2017

Can a commercial customer receive a Reg. Z statement for a commercial line of credit?

TIL Disclosures

07/31/2016

Is a Truth-in-Lending disclosure for HELOC the same as the Initial Disclosure?

Loan Estimate: Disclosing NO for the rate lock

05/22/2016

I have a question concerning the Rate Lock disclosure on the Loan Estimate. If we disclose “NO” for the Rate Lock and don’t set the rate until the Closing Disclosure is provided do we have to provide a Revised Loan Estimate before the loan closing? What if the interest rate does not change from the Loan Estimate to the Closing Disclosure?

TRID: Must the rate lock be written?

05/16/2016

In the last Compliance Action, there was a Rate Lock disclosure Q&A. My concern is not about the meat of the question, but about a comment regarding written rate lock agreements. It stated that the rate lock must be “written” to officially lock the rate per the TRID. I cannot find where TRID says that the rate lock must be written. Can you please point me to the section or other documentation requiring written rate locks? We are internally debating the discrepancy between TRID disclosures and the HOEPA/HCML issues related to setting the final rates.

TILA, TRID, and HMDA: Low appraisal, counteroffer and Loan Estimate issues

05/01/2016

What are lenders doing when an appraisal comes in low, and a counter-offer is made to the customer? Since we are mandated to issue a new LoanEstimate within 3 days; it’s a challenge for our loan officers to get their customers to decide in 3 days whether they want to proceed with an option such as PMI, secondary financing, lower amount etc.How are other lenders handling this?

Early TIL/GFE for 3rd Mortgage Loan

05/31/2015

We are making a 3rd mortgage loan to a current customer. It seems ridiculous, but as far as I can tell we need to provide an early TIL & GFE. Is there an exemption somewhere I have missed?

TIL/GFE Disclosures for HELOC to Purchase Home

05/18/2015

We are doing a Home Equity Line of credit to purchase a home, do we need to do TIL and GFE disclosures? Or are they exempt?

HUD Required for 1-4 Res. Homes Used for Rental?

02/23/2015

Do we have to prepare a HUD for 1-4 res. homes used for rental property?

Commercial Loan if Rental Residential Props?

02/02/2015

If a consumer (personal name) requests a loan to purchase 4 rental residential properties and pledging another one of their rental properties that they own free and clear for the equity down payment, would this not be considered a commercial loan regardless of the fact that they are purchasing residential 1-4 family homes?

New TIL Disclosures Required 3 Business Days?

11/17/2014

Are new TIL disclosures required 3 business days prior to closing the transaction if the interest rate and associated APR go DOWN by more than 1/8 of 1%. For instance 4.50% was disclosed initially, but rates dropped and now rate is at 4.00%?

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EGRRCPA’s Portfolio Qualified Mortgage

By Patti Joyner Blenden

COMPLIANCE Q&A: Successor in interest & exemption

Question: It is my understanding that on successor in interest we are generally not exempt. The successor in interest gets the protections of a mortgagor under RESPA and TILA.

APR Paid by Lender-APR Fee from Borrower?

02/17/2019

If an APR fee is paid at closing by the lender should it still count as a APR fee the borrower pays?

Updated Index for Discounted Rate on ARM Product

02/17/2019

We offer a discounted rate with some of our ARM products. We use the index at the time the rate was set to calculate the fully indexed rate throughout the entire loan and that is what is disclosed on the LE and CD. Under what circumstance would we locate an updated index from a the date of closing or within 45 days of closing and disclose a blended APR. Would this be a 2 time construction closing? We disclose based on once the rate/index is locked that is the rate/index we use when we close. Unless of course the loan is re-locked for any reason.

Notice to Commercial Real Estate Purchasers"

02/17/2019

What, if any, is the regulatory cite requiring the lender to provide the borrower a "Notice to Commercial Real Estate Purchasers?" It is related to CERCLA.

CFPB Update On Construction Loans (Perm Financing)

02/17/2019

We are being told that the CFPB has given an update on construction loans at the time of perm financing. We are understanding it to read that if you do the modification into perm financing (no new loan) it is not HMDA reportable. Does this mean a construction loan would never to reported if this is the case?

Savings Acct. as Collateral-Loan Fees

02/17/2019

For a loan with a savings account as collateral, can all of the loan fees (doc fees, credit report fees, etc) be included in the savings hold?

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