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.
If a bank makes a loan to a trust, for purchase of a dwelling, does it fall under TRID?
If real property titled to an individual's trust, do I need to provide the three day right to cancel?
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.
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 to a trust?
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
Ever since its implementation, the efforts to develop and implement a Customer Identification Program have been fraught with questions.
It's here. The Federal Reserve Board has signed off on proposed Know Your Customer ("KYC") rules.