01/28/2008
How do you handle not having an appraisal to assist in the calculation of flood insurance coverage for commercial or residential properties? Does the NFIP mandate that an appraisal be done?
04/01/2007
Risk has been a key term and management concept for the last decade, but we are still trying to understand what risk management means and to develop or refine techniques for risk management and ass
01/08/2007
I am preparing a GFE for a closed end home equity loan and have been informed that I must also provide the home owner's insurance premium and real estate property taxes before a GFE can be given. Why now?
11/20/2006
We are trying to comply with the FDIC SCANS bulletin # Chiro-04-2001 however we are having difficulty finding clarification as to exactly what is required. The FDIC is citing violations for the lack of disclosure of hazard insurance and taxes on GFEs and HUD-1 in a second lien and/or refinance transactions where adequate coverage is already in place and the bank does not require additional coverage or escrow for these items. The bulletin states that if the bank requires these items to be in place, they must be disclosed on both the GFE and the HUD-1 as paid outside of closing (POC). My first question is does the requirement apply to both hazard insurance and taxes? And secondly how are these items disclosed on the GFE and HUD-1, (i.e., are estimates based on current year totals divided by 12 months acceptable)?
05/08/2006
I attended a Mortgage Disclosure seminar last week and heard an unfamiliar stipulation, that if a property is determined to be in a flood hazard area, settlement can not occur for 10 days. I'm not sure if the 10 days starts from the date of determination, or from the date that the customer acknowledgement is received. I was aware that settlement could not occur until flood coverage is in place, but was not aware of any 10 day stipulation. Can you elaborate?
02/27/2006
We have been cited during a recent FDIC compliance exam for not including POC costs for hazard insurance and property taxes on the form HUD-1A, when the customer obtains a second-lien home equity type loan. We have never been written up for this before and the fees don't seem to fit in the categories provided on the HUD-1A. Are they really required to be listed?
02/06/2006
Is it necessary to disclose ad valorem/real property taxes on non-purchase loans? We never escrow this because the customer is required to keep taxes and insurance current. If it is a good practice to disclose this (POC) as we do hazard insurance, then how exactly is it disclosed? Is the tax amount that was paid for the previous year what is disclosed?
11/07/2005
1. True or False- In accordance with Reg Z, the disclosure of a finance charge would be considered accurate if the amount disclosed is greater than the actual final amount or if the amount of the finance charge disclosed is understated by $100.00 or less. 2. True or False- Prepaid escrows required by the lender for future payment of real estate taxes and hazard insurance premiums are considered finance charges for disclosure.
10/01/2005
Flood hazard insurance has been with us for a long time. Unfortunately, we still don't seem to be getting it right. Civil money penalties are assessed all too often.
09/01/2005
Have you ever gone back and looked at a law or regulation when it was just adopted and then compared it to today's version? Take CRA for example.