06/20/2011
An up front collected Appraisal Fee is more than the invoice. A lender credit is to be shown on the HUD. What amount is shown in the 800 series of the HUD as the POC amount and the Comparison Page? The actual cost of the appraisal or the amount collected from the borrower?
06/06/2011
My job has been to work on residential compliance. My boss has just taken over the servicing side for commercial loans.I have never worked with commercial loans before now. Where would I start? I understand that some of the Reg's encompass residential and commercial. What fees are allowed? Where would those do's and don'ts be found?
01/31/2011
When figuring out possible reimbursement for differences between the GFE and HUD 1, is the total reimbursement based on the total difference in charges (10% tolerance items) or is it on an individual basis? As an example, the appraisal fee is over 10% greater than GFE; however, the title insurance is 25% under the GFE. Can these be netted together or do we just need to consider the appraisal fee variance.
11/08/2010
Relative to the Dodd-Frank Mortgage Reform Act, Sec 1471 Property Appraisal Requirements: the Property Appraisal Requirements have an Interim Final Rule date of Oct 21, 2010. Is this a mandatory compliance date, i.e., for the two appraisal notices: [new] Consumer Notification Sec 129(H)(d) and [revised] Sec 701(e)(5) Right to Copy? I'm getting frustrated. No one can answer this question and I can't figure it out. I can't instruct to have these disclosures in place by Oct 21st if that is not the case. Relative to Second Appraisal Sec 129(H)(b)(2)(A): the lender needs to order two appraisals, correct? One to determine appraised value for the new higher-risk mortgage being processed and a second one to determine why this new sales price is higher than the sales price within the last six months... correct? See Pages 810 and 811 of BOL's online MRAPLA: http://www.bankersonline.com/df_titlexiv.pdf. I have listened to the archive version of BOL's August 31st webinar on "MRAPLA" three times and I can't hear the answer to my questions.
08/09/2010
This is a Reg O question. The bank has an REO property they wish to sell to a board member. An appraisal was obtained November 2009, prior to bringing the loan in as an REO. Now the bank wants to use this same appraisal to make a new loan to a board member. Can this appraisal be used or should a new one be obtained?
07/19/2010
Which reg states that a borrower cannot choose his own appraiser?
07/12/2010
According to the Patriot Act, "Know your Customer", when closing a loan for a new home purchase, do we verify the borrower's current address or the one he is purchasing?
07/05/2010
In the 4.26.10 issue of the Weekly Banker Briefing, guru Randy Carey answered the question about appraisal fees (which itself does not apply to our operations) and ended with, "There is no longer a required provider list required to be given to the applicant." I am unclear on the reference. We do not allow shopping for the appraisal, but we do allow it for one item we require. What is the specific reference?
06/07/2010
Under Reg B we are required to send out a notice of action taken within thirty days of receiving an application. If we require additional information, such as an appraisal, to make the credit decision, but do not receive that information within thirty days, will we be in violation of Reg B if notice cannot be sent until after the thirty days?
06/07/2010
Relative to denied loan requests, including home improvement loans, is the bank required to do the following: (1)gather government monitoring info (2)provide the servicing transfer disclosure (3)provide the notice "right to copy of appraisal report" even if an appraisal is not obtained?in violation of Reg B if notice cannot be sent until after the thirty days?