Vendor Guru Q&A - Lending

Latest Lending - Trust Accounts Topics

Reg Z Living Trusts-Apply to Irrevocable Trusts?

08/12/2018

I'm aware of the 2015 CFPB commentary in Reg. Z stating that living trusts should be treated as natural persons. Would this apply to irrevocable trusts (where the trustors are deceased)? Is there case law or commentary supporting (or not) that irrevocable trusts are estates and provided the organizational exemption under Reg. Z? Thank you.

Trust Loan-Dwelling Purchase: Fall Under TRID?

01/21/2018

If a bank makes a loan to a trust, for purchase of a dwelling, does it fall under TRID?

3 Day Right to Cancel (Individual Trust)

04/23/2017

If real property titled to an individual's trust, do I need to provide the three day right to cancel?

Trust - TRID ?

07/03/2016

A Trust owns a single family home which is currently rented. The owner of the Trust is deceased, so it is no longer an inter-vivos trust. A bank makes a loan to the Trust at a 14 year fixed rate, (5.99%) secured by the property. The Trustees are not personal signers, only the Trust is obligated. The loan to value is approximately 60%. Do TRID rules apply to this situation? Is a LE and/or CLoD required? What about ATR rules? The interest rate seems exorbitant.

Commercial vs Consumer Qualified Loan

05/25/2015

A loan comes to loan operations with the borrower being a trust. The purpose of the loan is to purchase 1-4 family dwelling for the trustee of the trust. Would this be a commercial or consumer qualified loan and why?

Does RESPA Apply To Loans For A Trust?

10/20/2014

Does RESPA apply to loans to a trust?

BSA: Designing Risk Assessment

11/01/2005

The annual Money Laundering Enforcement Conference co-sponsored by the American Bankers Association and the American Bar Association is always fertile ground for new ideas on BSA program management

CIP: When to Know What About a Customer

05/01/2005

Ever since its implementation, the efforts to develop and implement a Customer Identification Program have been fraught with questions.

At Last: The KYC Proposal

10/01/1998

It's here. The Federal Reserve Board has signed off on proposed Know Your Customer ("KYC") rules.

Consequences of Sending our Annual HMDA LAR Late?

05/09/2021

What are the consequences of sending our annual HMDA LAR late? I am new to this realm of lending. Who do I talk to, to discuss why it is late and does it help that we have never been late in the past?

Third-party Imaging vs. Core Imaging

05/09/2021

What are some reasons for considering a third-party bank imaging system?

Use of an existing determination

05/09/2021

If we are renewing, extending or increasing a loan do we need to do a new flood determination? Can it be recertified?

Advertising Rate Sheet-"Limited Time Offer"

05/09/2021

We are creating a rate sheet to be used by local Realtors. It will provide the current rates for several types of loan products. Under our in-house loan category, Marketing would like to list "Limited Time Offer" as one of the bullet points. I recommended they provide an expiration date. Marketing wants to show that as follows - "Limited Time Offer. May Expire Without Notice." Since UDAAP is governed by perception of the reader what are your thoughts, I am still leaning toward a hard expiration date. What is required, or commonly done?

UCC Search in Michigan

05/02/2021

Website for searching UCCs in Michigan?

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