Can a commercial customer receive a Reg. Z statement for a commercial line of credit?
Is a Truth-in-Lending disclosure for HELOC the same as the Initial Disclosure?
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?
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.
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?
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?
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?
Do we have to prepare a HUD for 1-4 res. homes used for rental property?
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?
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%?