03/08/2010
Does an escrow disclosure need to be given at the time of application or can it be given at closing?
12/14/2009
The handout for the Reg Z, New Early Disclosures webex indicates on page one that the HPML rules that go into effect on 10/01 do not apply to manufactured housing until 10/01/2010. I need a citation for this, as I can't find anything to back it up. I see where the escrow rules for these loans aren't effective until 10/01/2010, but I'm referring to the income, asset, obligation rules, etc.
12/07/2009
We haven't escrowed before and I was wondering, when establishing an escrow account or preparing a Good Faith Estimate, what is the easiest way to get the starting disbursement amounts? For how many months should the estimate be?
11/30/2009
While most new revisions to Reg. Z go into effect 10/1/2009, don't the escrow provisions go into place on 4/1/2010?
11/02/2009
We are looking into allowing voluntary escrow, and see that we have to adhere to the provisions of 3500.17 of RESPA. Are there any other concerns about which we should be aware?
07/13/2009
We require that our members have an escrow account to pay their real estate taxes, homeowners insurance and PMI bills. When a member pays off his first mortgage, are we allowed to deduct the escrow balance from the payoff amount or do we have to refund the balance of the escrow account to the member? We have attended compliance seminars that advise us to refund the balance to the member however, our system is set up to deduct the escrow balance from the payoff amount.
05/04/2009
Our bank currently does not escrow taxes and insurance. In a third party review it was stated that we should still give an estimate on the GFEs. Does the servicing disclosure have to be signed (RESPA)?
09/29/2008
We have a customer who is refusing to pay the increase in her taxes which has made her escrow negative. We have asked her several times to catch up, giving her several opportunities. We would now like her to pay her own escrow. Because of her refusal to catch up, are we allowed to discontinue paying her escrow for her? I have looked in the Consumer Compliance Manual and have not noticed anything about discontinuing the escrow payments.
06/25/2007
I understand that costs associated with no fee loans are to be shown as POC on the HUD. It is our practice to include the cost of the title, escrow and recording fees to the escrow company with our funding wire (over fund the loan). I have an escrow officer that refuses to show the fees as POC unless we send her a separate check and she won't even accept a separate wire for these fees. Her belief is that the items are not truly POC and this would constitute a RESPA violation. Therefore, she will only show it as a lender credit. I cannot find any information that suggests that over funding a loan constitutes a RESPA violation. Is this a RESPA violation, and if so, can you please guide me to the appropriate Reg?
04/09/2007
Does the annual PMI Notice need to be mailed or provided by January 31st each year?