04/17/2006
Are there limits on the amount a bank can charge a borrower for force-placed flood insurance? The Reg seems to leave it open, in that it says banks may charge the cost of premiums and fees incurred in purchasing the insurance.
04/17/2006
After the 3 day rescission period has passed on a HELOC, can we fund the line or do we have to wait for the "non-cancellation" section of the form to be signed, dated and returned to us? My understanding has always been that we can disburse after the three days as long as we have not received a "Wish to Cancel" back from the borrower.
04/17/2006
Currently, the appraisal fee for customers is paid by the bank, and disclosed as POC on the GFE. We will possibly be charging the fee for multi-family appraisals to the customer. How should the GFE be updated? Currently the GFE indicates Appraisal Fee #803 (POC). The fee will only be charged on multi-family/<WBR>investment properties. Also, in what time frame must the GFE be updated?
04/10/2006
What are the requirements for sending annual mortgage history statements to customers? We send the 1098 as required, but we are also sending a mortgage history statement to every account secured by real estate. Is this necessary?
04/10/2006
The Bankers Online webinar I attended a couple of days ago stated that flood insurance is required on construction loans prior to funding the loan. However, the insurance companies will not write the policy until the slab is poured. Can I have clarification on this?
04/10/2006
On a no cash-out refinance on a Home Equity Line of Credit, is a Notice of Right to Cancel required?
04/10/2006
I'm looking for some clarification on the Settlement date on the HUD-1, the closing date on the Note and Mortgage Deed, and the Rescission/Disbursement date. I'm thinking that the settlement date, the Note date, the Mortgage date, and the closing date are all one in the same. One of my co-workers is thinking that the settlement date should be the date the funds are disbursed which would be the date of the rescission. Is this correct?
04/10/2006
I have a HMDA loan on a mobile home where the title is being retired. The title is being retired because the mobile home is now permanently affixed to the property and will be classified as a 1-4 family dwelling. I need to know how to classify this loan for HMDA, 1-4 or Mobile home? Also I was wondering where I could find some literature on the retirement of a title.
04/10/2006
We have a loan that is for acquisition of a commercial property. However, the loan will be collateralized by the commercial building and a second mortgage on the guarantor's primary residence. Is the 3 day right of rescission applicable?
04/10/2006
Our mortgage lending firm over-discloses the TIL on all loans so that we do not have a potential under-disclosure issue causing us to re-draw documents or refund the borrower. A buyer of our loans in the secondary market just told us that we couldn't do this as a practice. Are they right? Are we doing something wrong?