09/22/2003
Is the HOEPA disclosure necessary for each and every closedend home equity loan or only the loans that meet the outlined criteria? Perhaps a better question would be this: do specific outlined criteria exist such that all the types of nonHELOC loans would ultimately fall under HOEPA?
09/02/2003
A home improvement loan was closed without giving the RESPA docs. Is there a 'cure'? Can we send the GFE, etc., after the fact?
06/30/2003
We have a customer who has struggled to make his payments on his mobile home loan. The mobile home is his principal dwelling and the original loan was purchase money. He was past due and we were about to foreclose when he asked if we could renew his note to get it current. He had changed jobs and after checking his income to debt and cash flow, we agreed to refinance the loan. Does the refinanced loan fall under HOEPA?
06/09/2003
I know that banks have an option on whether or not to report HELOCs for HMDA monitoring purposes. If we do choose to report them, what are the guidelines?
06/01/2003
We have been hoping for this ever since the changes to Regulation C were published.
06/01/2003
Implementing the changes to HMDA is not going to be easy.
04/07/2003
We are a financial institution that is planning to offer a promotion for home improvement loans. Along with the promotion we would like to have a drawing for some tools that will be displayed in our lobby. Customers who receive one of these loans will have their name in the drawing. Any laws or compliance issues that we should be concerned with?
03/24/2003
What should we do if a home improvement loan was initially applied for as a construction loan and no rescission form was given to the owners of the property? The borrower already received the money. Should we do a rescission form for the customer with a date in the future or try to match the note date? Our lenders periodically give us wrong loan request information and we have clean up work after the loan closes.
03/17/2003
HMDA exempts from reporting any loans that are for temporary financing. Temporary financing is not defined by the regulation; however, one definition used by banks is that a temporary loan is a loan with a maturity of 2 years or less that has a balloon payment and is to be repaid from other than earned income. Does this hold true for home improvement loans? What if a home improvement loan is amortized over 6 months or 12 months? Please advise me on whether or not short term home improvement loans are reportable on HMDA.
03/17/2003
Is a loan transaction HMDA reportable if the loan proceeds were used to purchase an air condition unit for the customer's son that will be in the son's house . The house is owned by the son, not the customer who got the loan. This is basically a gift from mother to son.