Filings on Mortgage Brokers
Regarding HMDA, we have two different answers as to what defines a Bridge loan. They are basically the same answers with one exception: if the loan is secured by BOTH dwellings (existing one and one to be purchased); OR if the loan is secured by ONE dwelling (either existing or one to be purchased). As I said, I understand consistency is the key to remaining violation free in this area, but again, I would like to know how the majority views this detail of a Bridge loan.
I understand that Reg Z requires us to set up an escrow account for loans that qualify for HPML. If the security is made up of separate tracts of land and only one of the tracts includes the first lien on a principal dwelling are we required to escrow for taxes and insurance on the other tracts of land?
We use a cross collateralization-cross default clause in all commercial loans. If collateral includes 1-4 family residences, in a refinance, is the loan HMDA reportable?
When we take a second mortgage, we send a letter to the first mortgage holder advising them of our second mortgage, asking them to verify the first mortgage balance and to refrain from extending any further credit or to make any further loans to this borrower secured by the same RE. We rarely receive the letters back confirming the balance. First of all, do we protect our lien in any way by sending the letter and keeping a copy showing we sent it? Would it be prudent to track until we receive these back?
I recently attended a Harland Laser Pro Regional Conference. It was indicated that the SAFE ACT states that mortgage lenders must register for a NMLSR. Does this include loan officers that just take Home Equity Loan and HELOC applications?
Can banks pass nonpublic client information across their lines of business? Example: Home loans passes information to a credit card line of business.
A local attorney has informed one of our bank officers that the SAFE Act would require a lender to be a registered mortgage loan originator in order to close loans for lot purchases (land only). I haven't heard that in any of the seminars I have attended. Is this true?
Is a consumer credit score disclosure required for mobile home loans if we are not taking a security interest in the land on which it is located?
Are funds held as collateral exempt from an IRS levy, or do these funds need to be included in the bank's response to the IRS levy received?