Vendor Guru Q&A - Lending

Latest Lending - Trust Accounts Topics

Rescission on HELOC if Revocable Trust?

06/06/2021

Should there be a rescission on a HELOC where the borrower/owner is a revocable trust?

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.

Pulling a Tri-credit Report for Fraud Victim

07/25/2021

We have a customer that is a victim of fraud. The customer called several different credit reporting agencies to get information and received several different answers regarding credit information. The customer wants us to pull a tri-credit report for them. Would this be a permissible purpose to pull the credit report?

Assessment Area Map for CRA Public File

07/25/2021

How does a bank best create an assessment area map and map of their county showing branch locations and census tracts for its CRA public file?

Disclosure Exceptions

07/18/2021

How can a bank track disclosure exceptions?

Mortgage Apps Chart for HMDA LAR

07/18/2021

Do you know of a chart that illustrates which mortgage loans/applications that are to be reported on the HMDA LAR?

Collateral Address- Real Estate Secured (TRID)

07/18/2021

When populating the collateral address for consumer closed-end, real estate secured loans (TRID), is there an industry best standard for WHERE we obtain this address from? I know that it must always include the zip code, and a location (if an address via US Postal Service is not available), but I'm curious if there is an unspoken standard of what document this is best obtained from, such as the counties property record card, the written evaluation provided to us from a certified appraiser, borrower attested to, etc.

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