This question pertains to lender credits on California loans. We have an SB2 charge from title on all refi's which is always estimated at the max fee of $225.00. This doesn't get updated until after closing when majority of the time it is lowered to $75.00. If the lender discloses a credit for this fee upfront at $225, can the lender credit be reduced if/when the fee is reduced at closing (after funding)?
Our conditional approvals are verbal and there is often not sufficient information in the file for the staff that prepares the HMDA LAR to know what conditions are outstanding. How can we report accurately in this situation?
When Title Fees are disclosed on the Loan Estimate in Section C (Services you CAN shop for) but the borrower chooses the vender on our provider list, we know that TRID rules now clarify that these fees must be moved to Section B (services you did not shop for) on the Closing Disclosure. However, TRID also says that we if offer the option to shop and the borrower chooses our providers, there is a 10% tolerance allowance, but in section B, the tolerance is $0. How can we correctly apply the 10% tolerance when the borrower can shop but chooses our provider?
I'm trying to determine if this commercial loan is HMDA reportable. The borrower is purchasing 295 acres. This mostly vacant land is used primarily for hunting however, there are two dwellings on the property. My question is, can this property be considered primarily agricultural? Referring to Reg. Z guidance on what is considered agricultural, fishing would fit this category but there is no mention of hunting. I wanted to get other opinions as we are leaning towards this being reportable.
It is my understanding that we must accept private flood insurance only if it contains the Compliance Aid statement. Correct?