Most Popular Lending Content
Disclosures on HELOC to Purchase Home
01/19/2004
What required disclosures to you need on a HELOC ifthe main purpose of the loan is to purchase the borrowers' house? They are only asking for $40,000.00? Do you need an early truth in lending disclosure or early good faith estimate and any other early disclosures?
Advance Notice of Hazard Insurance Force Placement
01/19/2004
How many days notice must we give a customer to obtain hazard insurance on a residential property before we force place insurance?
Rescission on HELOCs
01/19/2004
We routinely cross-sell HELOCs to purchase money mortgage customers, and close them simultaneously with the purchase money first (although HELOC funds are not used for the purchase). Our review of Reg Z seems to indicate that these HELOCs are subject to the 3 day right to cancel, even though at the time of closing, the borrower does not live in the home being purchased. Are we interpreting this incorrectly?
RESPA Disclosures Given BEFORE Application
01/19/2004
With respect to a real estate loan, we have a Loan Officer who completed and mailed the RESPA Disclosures prior to application date. They think they should not have to mail out any additional RESPA disclosures after we received the application because they had already been given. I question how they knew what figures to use since there was no application giving them the needed information.
Disclosures of Fees on Commercial Loans
01/19/2004
Our sister bank was told by their examiners that they were in violation for not disclosing fees such as overnight fees on commercial loans. What fees are required to be disclosed in this instance? We typically list the loan fee and flood fee on the note under Additional Charges. What, when, where should we disclose on a commercial transaction (real estate and non-real estate related)?