11/11/2002
The following is a question from a branch: Are you aware of a checking account for real estate firms that allows them to earn interest? I have been told by one of our customers that the laws recently changed to allow for them to earn interest. In the past, I have put them in a Commercial Money Market account, but that of course restricts their withdrawals.
11/11/2002
What are the regulations on charging a fee for flood certification. And can a bank charge the customer more than the bank paid for it?
10/22/2002
10/21/2002
We understand if we have a Real Estate Loan which falls under HOEPA, we are required to give disclosures 3 days prior to closing. We also give the customer the initial disclosures required by RESPA within three days after receiving their application. If the disclosures we give under RESPA are identical to what HOEPA requires and these disclosures, (for example), are given two weeks prior to closing, would the RESPA Disclosures fulfill the HOEPA disclosure requirements?
10/01/2002
Question: We are developing a new mortgage loan product for sale on the secondary market.
09/16/2002
I am the newly appointed compliance officer for our bank. I would like your opinion on first, if you think I have a problem and second, how would you go about solving it. Our retained legal counsel for the bank never returns our calls. He is a member of the board and therefore when brought to the board in the past, no one would vote to replace him. I have a big problem with making new policies without the advice of legal counsel. Am I correct for being concerned? If so, how can I convince the CEO and/or board that this is a problem?
09/16/2002
Bankers Compliance Consulting Real Estate Loan Matrix. I found on this web site indicates that a closed end home equity loan is not HMDA reportable. I would like to know the reason the author made that decision. I find the reg excludes open end lines of credit only...
08/01/2002
HUD has posed specific questions for comment. These questions seek open debate on specific issues that HUD believes may need clarification.
07/01/2002
Unless Congress stops it, HUD plans to make major changes to the Good Faith Estimate.
07/01/2002
HUD wants to simplify the real estate settlement process for consumers, augment the ability of consumers to shop for settlement services, and improve disclosures required by RESPA.