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Latest Compliance - Real Estate Lending Topics

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?

Loan Taking Land As Collateral But Not Mobile Home

06/02/2014

We have a loan where we are taking the land as collateral but NOT the mobile homes on the land. The property is in a flood zone but should we require flood insurance since we have no interest in the mobile homes?

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Paying out CTR-able cash, sans SSN

07/23/2023

We have a non-banking client who received several checks from his deceased grandmother (our client) which total over $10K. He is traveling from KS to Fla to cash these checks. Our problem is that he doesn't have a Social Security Number. Can or should we cash the checks and create a CTR, or refuse him? He does have a DL. He lives off the grid....we will file a SAR for sure.

Insiders and Overdrafts

07/16/2023

An executive officer has a debit card transaction that has caused an overdraft. As to Reg O, we would pay and charge the fee. But as to Reg E he has opted out which means we would pay the item and not charge the fee. I don't know which Reg takes precedence. The account is overdrawn less than $100.

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