04/23/2012
In Settlement Statement (HUD-1A), Secion 804 Appraisal fee Question. Normally, lenders receive appraisal fees at the loan application. In Good Faith, the fee will be disclosed. What is the proper method in recording the appraisal fee in the HUD-1 OR HUD-1A? Is it correct to record "the fee to ABC Appraisal Co in Section 804 as P.O.C." and in Comparison of Good Faith Estimates (GFE) and HUD-1A Charges, to record the fee in Good Faith Estimate and HUD-1A, althought the automatic software will not record the fee in HUD-1A)?
03/12/2012
I have a question in relation to Section 202.9(a)(1) of Regulation B which states that a creditor shall notify an applicant of action taken within 30 days after receiving a completed application concerning the creditor's approval of, counteroffer to, or adverse action on an application. Example: August 1st: Application is taken and loan receives preliminary approval subject to verification of income, property value, etc. September 6: Receive the tax returns from the client, income is much less than indicated by the client and it is determined that Debt-to-income ratio is too high and the loan will be denied. How should we handle this situation? Most of our 1st mortgages don't close within 30 days of application. If we are still waiting on info from the client when we are nearing the 30 day mark, should we be sending a letter of incompleteness? Reg states we can give them a reasonable period of time to provide the info. What do you think is reasonable?
03/12/2012
I read online a Right to Receive a Copy of an Appraisal notice is not required on a renewal note when pulling forward an existing appraisal/evaluation. Is this correct?
02/06/2012
What method(s) are being used to determine insurable value when calculating the appropriate amount of forced placed insurance?
12/12/2011
Reg O states that increases to existing indebtedness are not considered extensions of credit so long as "the additional funds are advanced by the bank for its own protection for accrued interest or taxes, insurance, or other expenses incidental to the existing indebtedness." Is a loan fee that was included in the amount financed included in this exception? Example: Executive Officer A has a loan for $100,000.00 with a $500 loan fee and an appraisal fee of $300 for a total amount financed of $100,800.00. Would this be a Reg O violation?
10/31/2011
Are we required to disclose on the GFE and Final HUD an appraisal fee for an appraisal ordered by another lender? The fee was paid by the borrower prior to applying for our loan. We are using this prior appraisal for our loan.
10/03/2011
Does a customer need to sign the appraisal notice for a Lot Loan?
08/22/2011
I'm new to BankersOnline.com and also to compliance. I am trying to find some training materials relating to the USA Patriot Act that I could potentially use as a model for staff training at our bank. Can you point me in the right direction?
08/08/2011
We have the opportunity to refinance a commercial real estate loan from a competitor. The subject property was appraised by an approved appraiser within the last 12 months. The appraisal was ordered by the competitor. The competitor bank won't release the appraisal directly to us, but the borrower has a copy. Our compliance officer says that we must order a new appraisal because accepting the copy from the borrower would violate the latest interagency appraisal guidance. Any options available besides a new appraisal?
07/18/2011
I am taking a mortgage on agricultural real estate and according to the appraisal an old shed is located on the land. It also states that the building has no value. Does a flood determination need to be done since the appraisal states the structure has no value?