Most Popular Lending Content
ARM Rate Disclosure Rules
10/04/2004
We have a product type is a 5/1 Arm based on a 30 year payout. The note rate is 4.875% with a margin of 2.875% and index of 1.210. The payments on $93,000 are being calculated at $492.17 for payments 1 - 60. The second stream of payments after the fixed period are being calculated starting with the 61st payment of $455.88, resulting in an APR is 4.399% (which is lower than the note rate). But the second stream of payments are calculated at todays index plus the margin and rounding to the nearest eight (4.125%). Our Auditing Dept. was questioning whether the second stream of payments of the TIL should be at the highest rate? The cap is 9.75%.
Reg. AA and Pyramiding Late Fees
10/04/2004
My read of Reg. AA is that taking a full regular payment and applying it to accrued but unpaid late charges, instead of to the current regular payment, is in violation of the regulation. This practice then causes the customer to become unfairly delinquent again. Is this correct?
Notice Timing for Appraisals
10/04/2004
For the Right to receive a copy of appraisal form, is this to be given at the time the customer gives us their application, or when we send/give early disclosures or when loan closes? It is my understanding from the regulation that it is at any time during the application (before credit decision is made) and I just want to know if I am interpreting this correctly.
Credit Bureau Reports Without Written Permission
10/04/2004
Can you take applications for loans over the phone and pull credit? If the customer never comes in and the request is denied, what do you do with the application that has not been signed by the customer that gives you permission to pull credit?
May We Require Related Services
10/04/2004
Is it permissible for our bank to offer a discounted mortgage rate if the customer opens a checking account and sets up an automatic payment?