Are we able to charge an annual fee on an overdraft line of credit and a
personal line of credit? (We are doing Business in Massachusetts). We are
looking for an open end product @ a fixed rate maximum APR of 18%.
When are the revised ATR/QM rules effective?
What happened to Appendix Q?
We chose to use the temporary GSE QM rule in the past. Is that option still available?
Are we required to offer seasoned QMs?
Are balloon payment loans still allowed?
Is there a pricing restriction on qualified mortgages?
We had a problem with debit card claims so we modified our deposit agreement. If they don’t cooperate in the claim process, we can deny it. Problem solved!
What is the “one-click away” rule for electronic advertisements?
I received the following question from one of our Lenders and I am having a hard time tracking down an answer:
"First lets define a Transactional Broker. In this context, a transactional broker is an agent that is not licensed. The agent will usually work under a supervisor. A transactional broker may be listed on a purchase contract, but they will be identified a Limited Agent (or similar language, sample contract attached). Transactional brokers are also called Statutory Brokers (often in WY) and occasionally Intermediary.
It is important to note that a licensed agent can work in a "Limited" capacity, but a non-licensed agent (Transactional Broker) can never represent a buyer or seller. That means, not all contracts with limited agents are "Transactional Brokers."
Assumption 1: When the agent is licensed, even when they are shown as working in a limited capacity, then their contact information is to be shown on page 5 of the closing disclosure (CD). Is this a correct understanding?
Do divisions have discretion on this point? Can they leave the contact information off in order to match the Seller CD produced by title? This is common practice by title companies in this area.
Next question, what is best practice when the limited agent is not licensed? Do we show non-licensed agents (Transitional Brokers) on the CD, without a license number, or do we leave their name off the CD?
Last point of clarification, it is our understanding that discrepancies in the contact information section of the CD (page 5) are to be included in the
post closing seller CD Review process outlined in the Seller Obligated Job Aid. Please confirm."