We have interest only lines of credit in our commercial portfolio. Will those be the ones we flag as having an interest only feature?
Do we complete the loans costs field and the points and fees field?
We have a customer who wants to finance the construction of a barn on his homestead property. The loan officer says this is business purpose because the customer will have a horse operation in the barn and earn additional income (he has a full time job). I disagree and believe TRID applies. Which do you think it would be and why?
Under TRID rules, what disclosures and timing requirements apply if our bank agrees to modify or amend an existing home loan? Do different rules apply if the maturity date changes beyond (more than) the original?
Loan Terms, Interest Rate: disclose up to two or three decimal places...rate is 5.30%; can it be disclosed as 5.3% or must it be 5.30% (two places)? We have seen some software disclosing as 5.3%.
If there is no Mortgage insurance at all should it be disclosed with a zero or a dash?
If we have issued a CloD and the rate expires and we need to extend it, then what do we need to do? The CloD does not show the expiration date.
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?
For the permanent phase of a construction to permanent loan, how would a voluntary escrow for taxes be disclosed on the LE and CD?
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.