Most Popular Lending Content
RESPA Escrow Disclosure on Manufactured Homes
09/10/2012
We make loans on manufactured homes, where the borrowers lease the land on which the home rests. We do escrow if the loan qualifies as an HPML. But do we have to also send out an Initial Escrow Account Disclosure Statement? 1026.35(b)(3) makes no mention of the statement. There is a reference in 1026.35((b)(3)(i)(2)of the Commentary, mentioning RESPA and the administration of escrow accounts, yet RESPA doesn't apply to these types of manufactured home loans. What to do?
HELOC Waiting Period Restrictions (Reg Z)
09/10/2012
Is a HELOC subject to any of the waiting period restrictions imposed by reg Z as of 7/2009?
Transfer Tax Fee for Settlement Charges
09/10/2012
We have a refinance in Virginia and before funding we discovered the loan needed a transfer tax fee as part of the settlement charges. Are we liable for curing this fee? Since escrow/attorney did not inform us that a refinance in the state of VA needed to include this fee.
Interest Extension for a Consumer Mortgage Loan?
09/10/2012
Can one do an interest extension for a consumer mortgage loan? HELOC?
Reprice Loan if Rates Lower Before Processing
09/10/2012
Our VP of Lending wants me to draft an agreement for our clients stating that we will charge a $500 fee to "reprice" their mortgage loan if the rates go lower during the processing of the loan (before the loan closes). For example, they have a 4% rate and now rates dropped to 3.5%, we will charge them a $500 fee to lower the rate from the 4% to the 3.5%. The rationale is that we might lose them as a client if we don't lower the rate, but need to charge the fee for our costs. I am not comfortable with this from a Fair Lending perspective and am not sure if this violates other regs.