Vendor Guru Q&A - Compliance

Latest Compliance - HUD Topics

Travel Trailer Considered Mobile Home or Camper?

01/30/2012

Is a travel trailer considered a mobile home or a camper for HMDA purposes?

Payable to Agent or Underwriter on 1103/1104 HUD

01/30/2012

On lines 1103 and 1104 of the HUD, should the agent or underwriter be listed as the payable to?

Rule on Charging Fee Greater than Credit Report

12/05/2011

Can a bank charge a fee that is more than the cost for a credit report?

FHA, HUD or USDA have to Comply with Reg Z?

12/05/2011

Do FHA, HUD or USDA have to comply with Reg Z? Are a GFE and a TIL exempt on a USDA subsidized loan?

RESPA: Using Appraisal from Another Lender

10/31/2011

Are we required to disclose on the GFE and Final HUD an appraisal fee for an appraisal ordered by another lender? The fee was paid by the borrower prior to applying for our loan. We are using this prior appraisal for our loan.

HUD Settlement Statement-Credit Report Fee

09/26/2011

I have a question about completing the HUD-1A settlement statement. The credit union pays the credit report fee on behalf of the borrower. The borrower pays other settlement charges. The credit union discloses an estimate of the credit report on the GFE form. When using the HUD-1A, how would you disclose the credit report fee to show that the lender is paying and not the borrower?

Attorney Fees Location on the HUDA 1-A

09/19/2011

Should the attorney fees appear on the third page of the HUD 1-A (which is the comparison sheet with the original Good Faith issued)? It is to our knowledge that they should only appear here if the borrower selects their own attorney to prepare their title work (not an option at our bank). Therefore, we do not include this comparison. Just wanting to make sure that we understand this correctly.

HUD Settlement Statement-Line for Owners Title

08/22/2011

What line on the HUD settlement statement should the owners title insurance be shown?

Amount Shown on 800 Series of HUD

06/20/2011

An up front collected Appraisal Fee is more than the invoice. A lender credit is to be shown on the HUD. What amount is shown in the 800 series of the HUD as the POC amount and the Comparison Page? The actual cost of the appraisal or the amount collected from the borrower?

Reimbursement for GFE/HUD 1 Differences

01/31/2011

When figuring out possible reimbursement for differences between the GFE and HUD 1, is the total reimbursement based on the total difference in charges (10% tolerance items) or is it on an individual basis? As an example, the appraisal fee is over 10% greater than GFE; however, the title insurance is 25% under the GFE. Can these be netted together or do we just need to consider the appraisal fee variance.

Next Day - Same Day Availability

10/27/2024

We were recently audited and it was noted that because a customer can immediately withdraw funds from a deposit made that same day, that we should be disclosing as a same day availability bank. instead of next day availability. What is your opinion and how do you recommend wording the change on policy, notices, and disclosures? It seems most examples I find are all next day examples.

Stopping Preauthorized Payments

10/20/2024

We currently have outside counsel providing what I believe is inaccurate guidance. However, I'm struggling to find resources I can use to refute their regulatory interpretations. Specifically, this applies to a consumer's right to stop payment under 1005.10(c). Can you please advise how these requirements apply to: 1. Preauthorized transfers for loan payments (we are the lender/servicer) drawn on both external (we obtain debit authorization) and internal deposit accounts; and 2. Preauthorized bill payments both issued against the bank's/vendor's account and debited directly from the consumer's account. We hold the consumer's deposit account and offer the bill pay service.

Latest Compliance - HUD Topics

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