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Latest Compliance - Real Estate Lending Topics

New TRID disclosures- Reg Z

02/27/2016

Does a loan to a consumer to purchase vacant land for investment fall under needing the new TRID disclosures?

Record Retention: Secondary Market Loans

02/14/2016

We are an electronic filing bank. All of our documents are scanned in and hard copies then shredded. On an MPF file (loans that are Secondary Market loans), how long do we need to keep the file once the loan has been sold/paid off?

Fee for Future Mortgage Releases-County Clerk

01/31/2016

Our bank collects a fee for future mortgage releases. Even though at closing the fee goes to us, eventually it is paid to the county clerk when we release the mortgage. For the purpose of the Loan Estimate and the Closing Disclosure is this fee considered paid to the Lender or to the County Clerk? Either way it would still be a 10% Tolerance category correct? If it is paid to the lender would that mean it needs to be included in the finance charge that affects the APR for calculating HOEPA?

Credit Sales and Integrated Disclosures

01/03/2016

Prior to Integrated Disclosures, a credit sale (selling and financing an OREO property) required us to disclose the Total Sale Price on an Estimated and Final TIL (12 CFR 1026.18(j)). Is there a similar requirement on the new Loan Estimate and/or Closing Disclosure or has this gone by the wayside?

Condo Questionnaire Fee- New TRID Rule

12/27/2015

Under the new TRID rule, where would a Condo Questionnaire Fee be disclosed on the Loan Estimate? The questionnaire is required for the transaction but some condos may or may not charge such fee.

TRID's Services 10% Cumulative Tolerance

12/20/2015

In regards to TRID's services that a consumer is permitted to shop for, if the customer does not select a service provider and requests that the lender choose a service provider for them, is the amount charged subject to the 10% cumulative tolerance?

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Error Claims and Provisional Credit

09/17/2023

A customer purchased KETO Bites and states the cost was $39.99. She immediately received an invoice along with charges to her account for the amounts of $59.99 and $239.99, not for the $39.99. Does provisional credit need to be given for those amounts and is the dispute considered fraud?

Info for Filings of a Marijuana Limited SAR

09/17/2023

I am looking for guidance on what information to include on subsequent filings of a Marijuana Limited SAR. I followed the guidelines on Fin-2014-G001 for the initial SAR - and now have a 90 day coming due. I'm looking for any suggestions or documentation?

Where must what sign be?

09/10/2023

I am looking for regulations or guidance on signage/poster needing to be displayed in financial centers. We have an all-in-one compliance poster that includes Funds Availability, CRA Notice, Home Mortgage Disclosure Act Notice, Equal Housing Lender Notice, Equal Credit Opportunity Act Notice, and CIP Notice. I am looking for guidance on where this poster can and can not be posted in a financial center.

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