06/14/2015
Is it acceptable to use the RCV from the flood insurance policy rather than the hazard policy? I have seen many contradicting statements related to the use of one over the other.
04/06/2015
Two questions related to the recent revisions to Reg Z. 1) Does a business purpose loan partially secured by residential RE now fall under Reg Z? Do you need to have a NMLS license to discuss RE secured products with customers, including abundance of caution liens.
03/09/2015
Regulations state that the lender must deliver the appraisal to applicant at least 3 days before closing. Does this mean we can close on the 3rd day or do we need to wait until the 4th day?
02/09/2015
How long should the appraisal request log/sheets be kept? The logs are saved on our system. But we have a paper copy in notebooks.
02/09/2015
When are we required to use the Fannie Mae 1003 application for consumer real estate loans? We know we need them for 1st mortgage lien positions but what about 2nd Lien Positions?
01/26/2015
Can a loan be done on a single family residence (principal dwelling) with variable interest payments but a set principal payment payment?
01/19/2015
Is the Reg B Appraisal Notice required for loans to builders of residential properties?
01/19/2015
Our bank would like to engage in an affinity program with several large companies in our community. The program is intended to offer secondary market purchase money mortgage loans with discounts, such as: waived origination fees and a lender credit of $500 to be used toward third party origination costs. We do not have any partnerships/ownership stake with our third party vendors. Once established, the program incentives will be offered to any employee of the company regardless of salary level, full-time versus part-time, tenure, etc. Of course, all normal credit policy guidelines apply before final approval is determined. We are a small community bank with approximately $650 million in assets.
My questions are:
1. Should we be concerned about any fair lending, ECOA or UDAAP violations as a result of our special program offered only to specified borrowers?
2. How should we document the program to avoid any concerns of disparate treatment?
09/15/2014
I have a loan located in a flood zone. The appraisal is $105,000 with a $102,000 land value leaving the one building on the site a value of $3,000. I know flood insurance is not required on loans of $5,000 or less and a term of one year. Is there anything in the regulation that has a threshold for the building's value? If so, what is that value?
09/15/2014
Do mortgage loans follow the sames rules/regulations as checking accounts in regards to offering a cash or gift card when an account is opened. For example, could we book a mortgage with up before 12/31/14 and receive a $100 Home Depot gift card? Does this violate anything, and if not, what kind of disclosures would have to be paired with such a statement?