02/06/2012
Under the current Truth in Lending payment schedule guidelines, payments on FHA loans with MIP are shown as …for example 111 payments $1782.57 to 1726.23 249 payments $1489.01. I believe the correct input in APRWin would be: 111 $1726.23 And then 249 $1489.01. Why is the input valid using the lower payment amount ($1726.23) and not the higher ($1489.01)?
01/30/2012
Does Regulation B now require us to collect monitoring data on HELOC apps if we do not report HELOCs on HMDA?
10/03/2011
Is GMI collected on co-signers for HMDA applicable consumer loans?
05/23/2011
A loan to purchase an RV or a boat/yacht is used as a principal dwelling. Does this require the collection of GMI under Reg. B?
02/28/2011
My question is about collection of GMI for HMDA where we are providing both a 1st mortgage and simultaneous 2nd. Our mortgage dept. takes the app for the 1st, then sends a request to the consumer loan dept. for the 2nd. The consumer lender almost never has contact with the applicant. Are they required to collect the GMI again or can they use the GMI that was collected by the mortgage lender?
01/03/2011
We are not a HMDA reportable institution. Our bank was under FDIC receivorship. We were a State Chartered Bank, and we are now a National Bank. Since we are not required to report HMDA at this time, are we allowed to gather GMI on the initial 1003 for a real estate loan, or is this a violation of Reg B?
09/20/2010
Our compliance department has determined that GMI is not required for mobile home loans without land. Is this correct?
07/26/2010
An applicant refused to answer any of the monitoring questions during a telephone application, but during the review of the typed application, he marked the appropriate boxes. Do we include the updated information on the HMDA LAR or leave it as things he does not wish to disclose? The HMDA "Getting it Right" says that we are not required to report the information, but the FFIEC Q&As say that it would be a violation to report the updated information. Could you please tell us if it is a violation to include the customer provided information and share the basis for your answer?
07/05/2010
If a customer is using his unencumbered personal residence to purchase a vacation home, is GMI required?
08/10/2009
A customer recently purchased a second home, with the intentions of it becoming his primary residence after renovating. We did not finance the purchase money, but made the improvement loan. Upon the sale of their current primary residence, they will pay off the improvement loan. The term is one year. The loan officer treated the loan as investment property, stating "not homestead...not subject to RESPA." I find only one sentence in Sec. 3500.5 that would exempt this transaction from RESPA regarding "Any construction loan for new or rehabilitated 1- to 4-family residential property...is subject to this part if its term is for two years or more." Everything else I read indicates that this transaction is subject to RESPA. Am I correct? We are not a HMDA reportable bank, but it also looks like obtaining GMI applies. Can you please advise on both issues?