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

CIP: When to Know What About a Customer

05/01/2005

At Last: The KYC Proposal

10/01/1998