We are considering taking loan applications online. What are some key things that need to be considered as we go through this process? What questions should be asked?
Are initial PMI disclosures required on non-owner occupied purchase transactions?
According to Reg P, a financial institution is not to give out any account information, including account balances and account status. We regularly get calls from other financial institutions, companies like Comdata, and individuals asking if a check or ACH will clear. Are we allowed to give out that information under Reg. P?
In reviewing the FAQs from HUD concerning Early Disclosures (GFE), a loan originator must issue a GFE no later than 3 business days after the loan originator receives an application or information sufficient to complete an application. Application is defined as the submission of a borrower's financial information in anticipation of a credit decision relating to a federally related mortgage loan, which shall include the following: (1) borrower's name, (2) borrower's monthly income; (3) borrower's social security number to obtain a credit report; (4) property address; (5) estimate of value of the property; (6) loan amount and (7) any other information deemed necessary by the loan originator. When we receive an application online, it does not contain all the documents listed in our "application" (sales contract). Are we still required to send the GFE based on the information received that is considered "sufficient to complete the application".
During one of our recent exams, it was suggested by the examiners that we open accounts online (which surprised us); they would like us to phase out our brokered deposits and felt we could replace these deposits by opening accounts online. I have been trying to gather some information on what is involved in opening accounts online, in particular the risks involved; how to handle CIP, how to handle disclosures and how to obtain the initial deposit. I put out a question on Banker Threads, but did not receive much information. Can you direct me to any information that would help?Also, our president would like me to do a comparison to Free Checking - the pros and cons vs online accounts. While I have not experienced opening accounts online, I have been at a bank (some years ago) that offered free checking and we had a good experience. Few losses, customers really liked not having to worry about a maintenance fee, and the average balance tended to be around $3,000. I was wondering if you could direct me to any other sources that might be able to provide information or statistics on free checking?
We are deciding whether or not to provide e-statements on our internet site. What are the required disclosures needed to provide this service? I understand that the customer can choose whether or not to receive his/her statement electronically.
In a question that was posed to Patricia Cashman on 7-19-10 concerning HPML and modifications, she stated that escrow will not apply to a true modification. Could she please show me where that can be found in the regulation. I have looked and can't find this. I have this situation and I need more clarification.
We have a mortgage preapproval program as defined by 203.2 - a preapproval program as a request for preapproval for a home purchase loan is an application under paragraph b(1) of this section if the request is reviewed under a program in which the financial institution, after a comprehensive analysis of the creditworthiness of the applicant, issues a written commitment to the applicant valid for the designated period of time to extend a home purchase loan up to a specified amount. Section 3500.2 defines an application as the submission of a borrower's financial information in anticipation of credit decision relating to a federally related mortgage loan, which shall include the borrower's name, the borrower's monthly income, the borrower's social security number to obtain a credit report, the property address; an estimate of the value of the property, the mortgage loan amount sought, and any other info deemed necessary by the loan originator. The six items to trigger a GFE requirement are property address, loan amount, monthly income, estimated value, borrower name, and social security. Since a property address is not known on a preapproval, is a GFE required? What if we request verification of income? Does that not trigger a GFE on a preapproval even if the property address is unknown?
When a consumer loan is secured only by real estate, the title to the mobile home that rests on the property is not taken as collateral. Should early disclosures be provided to the customer or can the loan be treated as if it is vacant land?
When is an application subject to RESPA, requiring disclosures to be sent? Is it when you have taken the initial 1003 by phone or email, or is it when you have a signed 1003 by customer and have verified income and assets, etc?