If we are doing a second lien on a primary residence and the first lien was secured before April 1st, will we have to escrow this loan?
When making business loans to a corporation or an LLC who within the corporation or LLC should be required to sign the loan documents? In the case of a corporation, should all the officers of the corporation sign or can just one of the officers of the corporation sign? In the case of the LLCs who can sign on behalf of the LLC, for example, let’s say that I get a copy of the Articles of Organization and there are three members and the LLC is member managed. Should all three members be made to sign the loan documents or can just one or two to bind the company?
We have an application for a temporary (less than twelve months) home improvement loan to be secured by the principal dwelling. This loan will be done as a multiple advance, closed-end loan, while the project is being completed. Once the project is completed, this loan will be re-written into a term loan. Is the temporary loan exempt from the HPML requirements? Is it considered a "temporary loan" for this purpose?
For a loan on a home in which we do not escrow and the borrower pays his own real estate taxes, do we include the amount on the new Good Faith Estimate? If so, where, and where in the Reg does it say to do so?
Because of the HPML escrow requirements, our bank is just getting started with escrow. Do you have any advice for procedures and getting the system in place?