09/15/2003
Is the grantor of a trust required to be given the Truth in Lending disclosures when a loan is made to a trust?
09/15/2003
On a mortgage TruthInLending disclosure, there are two boxes to check that i am not sure about. One is the "REQUIRED DEPOSIT: The APR does not take into account your required deposit." The other box is "DEMAND FEATURE: This loan has a demand feature." Does the "required deposit" refer to the items deposited with the lenderthe escrow account. or does it refer to the downpayment on a purchase transaction? Does the "demand feature" refer to a balloon loan?
09/15/2003
We currently have a floor on our equity lines. Our senior lender would like to waive the floor for any customer (new or existing) that will set up an automatic debit from their checking account to make their monthly payment. Would we need to provide anything in writing regarding the new rate for our existing clients that opt to do this?
09/15/2003
Right of Rescission: After the rescission period has expired, if the creditor is "reasonably satisfied" that the consumer has not rescinded, can the creditor disburse funds without customers signing the notice stating they are not rescinding the transaction?
09/15/2003
What is HOEPA?
09/15/2003
I noticed comment in Memorandum for update pages in a Mortgage Lending publication the following:"Several U.S. Circuit Courts of Appeal have disagreed with the Department of Housing and Urban Development (HUD) on whether mark-ups of third-party charges are violations of RESPA. For example, may a lender pay $15 to a credit reporting agency for a report and then charge the customer $30 for the report at closing and keep the $15 difference? HUD has said this would be a violation of the Real Estate Settlement Procedures Act (RESPA) and several courts have disagreed." Do you have any information concerning these court findings? Can this be done with this 3rd party charge or any others? Example; Could we charge for "payment coupon books" related to a mortgage loan payment?
09/15/2003
With respect to the Soldiers and Sailors Civil Relief Act (SSCRA), I understand debts incurred prior to entry into the military are subject to the 6% interest rate cap. Does it matter whether or not the military member voluntarily enlisted in the military? I thought the SSCRA would apply only if someone was drafted into the military.
09/08/2003
09/08/2003
09/02/2003
I am trying to find out some information on the average age of an automobile when the loan goes bad. Do you know where I can find some statistics on repossessions? I want to extend the age of an used auto that we will loan on. Currently, we only make a loan on autos up to 5 years old. I would like to loan on autos up to 8 years old.