Under the new HPML regs (226.35), escrow of taxes and insurance is only required if you are "extending a loan". If we are doing a rate modification on an existing loan, HPML calculations do not apply. Is this correct?
When doing a short term commercial loan for materials and citing an existing mortgage as collateral, would a new flood determination be required?
Do all one to four family homes, rental properties etc., require RESPA? Does twenty-five acres with a home on the twenty-five acres require RESPA?
Due to the amendment to Reg Z and the passage of the higher education loans, our bank has taken a stand that we will not do any loans for student loan purposes. We had a borrower apply for a loan for a summer masters program and we have denied it as "requested terms not offered." The customer wants to reapply for a personal loan for debt consolidation. With the prior knowledge of the student loan, would we be in compliance if we were to do a bill consolidation loan and direct the checks directly to creditors (i.e., credit cards)?
On April 12, there was <a href="http://www.bankersonline.com/compliance/guru2010/gurus_comp041210d.html">a question</a> concerning credit bureau reports and how to disclose them if the lender does not charge for a credit report. The answer was that it should be listed in Block 3 and a negative amount in Block 2. Which line would we check in Block 2? Why would this be shown as a negative amount on line 802, when the charge isn't for a specific rate but for a credit report? The answer didn't address the fact that the lender doesn't charge for a credit report. If we don't charge, do we still need to include it in Block 3?