04/06/2009
Our bank is preparing to provide a blank real estate loan application on our website which the applicant can print off, manually complete and bring into the bank. Do we have to provide a CHARM booklet and loan program disclosure on our website with the blank application?
03/23/2009
When a real estate purchase loan goes to a closing company they prepare and send the HUD for the bank to approve. When they disclose fees such as appraisal, credit report and flood they show the funds being paid to our bank instead of the actual service provider. Are we headed down a bad road?
03/02/2009
If our institution charges an appraisal review fee and the review appraiser is an employee of the bank, is that charge considered a prepaid finance charge for Reg Z?
02/09/2009
After over twenty-five years of issuing preliminary TILs in certain home equity loan transactions, my new bank is telling me it is not required and only necessary at closing. What's the truth in truth in lending?
01/12/2009
In the HUD settlement for a purchase of a 1-4 family dwelling for rental purposes, the title company included a broker fee in addition to the commissions earned by the real estate company as part of the settlement to be paid at closing by the buyer/borrower. Should we accept this as part of our settlement without proof that the fee was earned by the real estate agent? Assuming it is a legitimate fee, should this be disclosed as a finance charge for APR calculation?
11/10/2008
Does a Reg B joint credit apply only to individuals applying for a loan or does it also apply to businesses? We have talked with banks that are utilizing Reg B on business loans if two or more individuals are guaranteeing the loan or if the loan is to an individual and a business. It is my understanding that Reg B joint credit applies only when two or more individuals are applying for credit for either a consumer loan or a business loan. Is this correct?
09/29/2008
I want to verify a procedure on collection of government monitoring information on residential real estate applications. If an application is a telephone application at what point are you required to have the government monitoring data collected either through the customer completing or through visual observation? We have an associate questioning whether the data has to be collected at all on a telephone application. We have been collecting it on the final application signed at closing on telephone applications. What is correct?
09/08/2008
What preliminary three day disclosures are required when you have a complete application with a property? What FHA disclosures are required?
08/18/2008
What are the penalties if a bank goofs up and places a loan ad in the paper that says $500 down and leaves off the proper disclosures that are required for trigger terms?
08/11/2008
Our compliance officer has indicated taxes and insurance should be listed as a POC on the HUD and Good Faith Estimate. Since property taxes in our area are paid in arrears and verification is obtained that taxes for previous periods have been paid prior to closing, why then list as a POC? If this is the case, why wouldn't we list taxes for all previous years since they are also required to be paid as a condition of the loan?