Vendor Guru Q&A - Lending

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.

Loan Portfolio Metrics

06/28/2020

What are loan portfolio metrics?

Additional Borrowers

06/28/2020

How many borrowers can apply using a single Uniform Residential Mortgage Loan Application?

ARM Notice After the Fact Circumstances

06/28/2020

We have a HELOC originated in 2008 that moved into the repayment phase in May 2018. The initial rate was WSJ prime and remains at WSJ prime (no margin) throughout the repayment phase. The loan has a interest floor of 3.75 percent so the rate has been set at that since May 2018. Since there is no set change date to enter in our system the CFPB ARM notice will not generate to give advance notice if the rate increases. Are we required to provide the ARM notice, and if so are these circumstances that allow the notice to go after the fact?

Notice of a Change in Terms for Credit Cards

06/28/2020

Is there any standard format to send notice of a change in terms for credit cards?

Title & Real Estate Settlement Co- Market Services

06/21/2020

Can I hire my brother who is in the mortgage industry, to refer business for a newly formed title settlement company? Can a title and real estate settlement company market services together? Does that person have to be a partner or employee of the business to not violate RESPA?

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