02/17/2014
Some of the loans we make are HPMLs. A few customers that were required to escrow for the one year minimum are now requesting cancellation of their escrow. However, we are receiving mixed opinions as to whether or not, with the new changes, that is an option. I would think if they were told 12 months when that was the Reg, that they should not have to maintain the escrow for another 48 months. Can you please clarify?
02/10/2014
We are going to start offering Debt cancellation insurance on 2/1 replacing credit life, etc. We can set this monthly in and out fee up on our core system as Other Escrow but need some clarification if this is going to make the loan be required to run through an escrow analysis every year? These payments would never change, a payment would collect then wash out immediately to CSO.
12/16/2013
Main bank and two branches are in rural/underserved counties. One branch is in an MSA. Will this affect our Small creditor status?
07/15/2013
RESPA/TIL question: We have a residential purchase loan where the attorney who closed the loan did not (also) provide the title insurance policy. FDIC states we have a TIL violation b/c we did not disclose the attorney's fee as a prepaid finance charge. We are not familiar with this being a part of TIL. Your thoughts please.
05/27/2013
Has the escrow calculator been updated and is this available?
03/11/2013
Scenario: Consumer purpose balloon loan that was originally the borrower's primary residence and fell into the HPML category. The borrower no longer resides in the property and it is now a rental. Since the purpose has changed from consumer to business, do HPML rules still apply? Can we cancel the escrow account? FYI-we are still within 12 months of origination.
02/11/2013
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?
07/30/2012
If we change the escrow rate for our escrow accounts, do we have to send the customers a notification of the rate change like we do when, for example, the rate on an adjustable rate mortgage changes? If so, how long do I have to send it to the customers?
07/23/2012
Are there any available cures if an HPML is closed without escrow?
07/16/2012
I have a customer whose escrow payment for taxes was estimated at time of closing because his purchase was a new construction. The tax bill was not actually what we thought and we sent back a check for roughly $2500. His bill this past year went up and now the escrow account is short about $3600 compared with where it needs to be. We have just started escrowing in the last two years on all loans. Do we have to give the customer the option to pay in a lump sum or make it up through his payments or can we require a lump sum payment now?