04/21/2014
We have a property that is in the flood zone and is collateral on three loans. On two of those loans there is multiple collateral. How do we calculate the coverage amount needed?
02/24/2014
Our bank is in PA-the property is located in OH.We wish to foreclose on the loan, issue the 1099C, but not take ownership of the property (deed in lieu). We are willing to charge off the loss rather than spend the money to rehab & market the property. Are there any laws prohibiting us from not taking ownership?
02/10/2014
Per new Regulation Z requirements, if we are a bank that has under 1000 mortgage loans, are we exempt from sending out the mortgage billing statements and the new rate adjustment notices for adjustable-rate mortgages?
01/27/2014
We are a small community bank operating in a predominantly rural community. In many instances, we may have multiple mortgages on a dwelling, cross-collateralized across a customer's loan portfolio.
In determining compliance for the CFPB Mortgage Rules, there are several references to first-lien transactions, Reg B Appraisal rules for instance. If our bank is the only secured creditor with multiple security instruments, are all of the mortgages considered the first-lien or is the first-lien the earliest dated mortgage and all subsequent mortgages are considered junior liens?
01/20/2014
We used to have a HELOC product but have discontinued all HELOCs. Our previous HELOCs are reaching maturity and we would like to modify them to closed-end products with either fixed or variable rates. Can we treat this as a modification or do we have to treat it as a refinance? If we have to treat it as a refinance it will be much more expensive for the borrower because we are in a state that requires an attorney closing for refi?
11/25/2013
The HMDA Getting It Right Guide has a definition of what a dwelling is. So, what about this scenario: A borrower gets a loan to purchase the lot next to their primary residence. On that lot is a home that has not been occupied for 20 years and is not habitable because the ceilings have fallen in, the floors are rotted, etc. and borrower intends to demolish it. Do we need to report this loan as a home purchase on our HMDA LAR? Or can we view this as a land purchase?
06/07/2010
What is the definition of Supervisory LTV? I find many articles on what they can do, but what is the actual definition?
06/18/2007
I have two questions specifically geared toward loan skip-a-payment programs. Can real estate secured loans be solicited for skip-a-payment programs? Is this skip-a-payment program considered an extension? (We follow a six extension rule.) Any help you can give on this subject would be greatly appreciated. It has caused quite a controversy between our audit and compliance area.
05/02/2005
am new in a compliance position and am having difficulty in real estate compliance. All of the matrices that I have don't contain all of the scenarios. For instance "Land purchase and construction". When do preliminaries disclosures apply. I need resources.
02/02/2004
Is there a compliance issue if you make an exception to your fixedrate home equity policy in order to extend the loan to value ratio from 80% 95% for one customer?