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Latest Compliance - Real Estate Lending Topics

Reg That Has Threshold for Building's Value

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?

Do Mortgage Loans Follow Same Rules As Checking?

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?

Forgot to List Private Party Expense: Re-Disclose?

06/16/2014

Our bank is financing the purchase of a home. Buyers are currently renters and are now purchasing from the estate. Buyers do not have the required 20% down payment so they are entering into a second mortgage loan with the Sellers/Estate. The initial disclosures did not mention the $30.00 mortgage recording fee for the mortgage the Buyers and Sellers will have between them. Do we have to re-disclose because we did not list the private party loan expenses?

Homeownership Counseling Notices for HELOCs

06/09/2014

Does the homeownership counseling notice need to be provided on open-end home equity lines of credit? This is a RESPA requirement, and our HELOCs are not subject to RESPA.

New ECOA Valuation Rule Apply to Home Builders?

06/09/2014

Regarding the new ECOA Valuation Rule that amends the appraisal provision of ECOA's Regulation B. Would it apply to home builders? I can't find anything in the regulation that it wouldn't.

ATR and Verifying Employment with Pay Stubs

06/09/2014

We are having a debate regarding ATR and verifying employment with pay stubs. The reg states you may use third party records and the definition of a third party in the regs state a document or other record prepared or reviewed by an appropriate person. Is using the most current pay stubs acceptable as verifying employment?

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Reg E and mobile payments

09/24/2023

Our customer received a call telling them their CashApp account was compromised, and they needed to verify the password. After they did this there were several authorized CashApp transactions. Can we tell the customer they have to resolve the issue with CashApp?

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?

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