Vendor Guru Q&A - Lending

Sharing Exception Reports with Lenders

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%?

Premium Content View All

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.

CFPB loses TRID ‘black hole’

by Patti Joyner Blenden

HMDA GIR Mixed Use Properties

10/14/2018

We made a loan to a non-profit for the purpose of acquiring and renovating 10 different properties. Loan is construction - perm. Eight of the properties are residential and the other two properties are commercial. The majority of the square footage (about 72%) of the total square footage of all ten properties is commercial. The two commercial properties are strictly commercial (not mixed use). The commercial properties comprise about 39% of the net collateral value, although the majority of the property values are lender's valuations, and not actual appraisals. I've looked through the HMDA GIR and do not see where this situation is addressed, unless I've overlooked it. The closest situation I could find addressed mixed use properties. In those situations, it stated it was at the lender's discretion, citing use of square footage or value. So I have square footage leaning to commercial (exempt) and value to residential (reportable). Would this be HMDA reportable?

Home Equity Loan: Improvement or Cash Out Refi?

10/14/2018

We are brand new to HMDA due to purchasing a branch in an MSA. We will start inputting in 2019. Our question is, if we have a home equity loan (we do not do LOC'S on home loans), it is to refinance existing mortgage and other funds are used for improvements to the property. Would that be a refi, home improvement or cash out refi?

Closed-End Threshold Test: Count Purchased Loans?

10/14/2018

Do we count purchased loans for the closed-end threshold test to determine if we are a small filer under HMDA? 1003.3(c)(4) states that the purchase of an interest in a pool of loans is an exempted transaction under HMDA, however I do not think that this includes mortgage loans purchased as a pool of loans. Thank you!

Getting Escrow Statements in Sync

10/14/2018

Doing annual statements is a real pain every month. What can we do to make these easier?

Loan Created in Signers Name-Company Debt

10/14/2018

A customer is signing for a company and owns 25% of the company, if a loan is created in the signers name would the companies debt need to be included in aggregate debt?

Latest Lending - TILA Topics

Pages

Pages

Pages

hot right now