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%?

Premium Content View All

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.

Lender Chooses to not Read HMDA Telephone Script

06/16/2019

What happens if a lender chooses not to read the HMDA Telephone Script when required to an applicant?

RCBAP Master Policy Acceptable Form of Insurance?

06/16/2019

Is an RCBAP master policy an acceptable form of insurance for a property that is legally a planned unit development (P.U.D.) and not a condo? FEMA guidelines seem to indicate RCBAP's can only be written on condos but we are seeing insurance agents issue these on P.U.D. properties with the insured name being the HOA.

2 Separate Security Agreements-1 for Each State?

06/16/2019

If we have a customer that has their business registered with the Delaware SOS however they live in ND, do we need to produce two separate security agreements, one for each state? I noticed this changes in the governing law section of LaserPro documents.

Tolerance/Cure Amount for LE/Closing Disclosure

06/16/2019

I'm new to TRID and trying to understand tolerance and cure amounts for things such as the following: Loan Estimate : - Recording Fees $32.00 - Settlement Agent Fee $500 and - Title Search $300.00 Closing Disclosure: Title Search $500.00 What would be the tolerance cure?

Home Equity Loan-Close at Home if Bedridden?

06/16/2019

On a home equity loans made in Texas, the law requires that they must close at an attorney's office, Title Co or the bank. If customer is bedridden can it close at their home?

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