02/28/2016
The CFPB recently posted an update to what the difference is between a preapproval and a prequalification.
Has there been a change in regulation that minimizes Preapprovals?
02/27/2016
Does a loan to a consumer to purchase vacant land for investment fall under needing the new TRID disclosures?
02/21/2016
Does increasing the amount of an existing consumer construction loan without extending the maturity date trigger TRID?
01/31/2016
I have an ARM servicing question. Does the timing of the initial rate and payment change need to be stated in the Note?
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?
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?
01/03/2016
Our bank collections dept is being asked to transfer credit card payments from a closed acct to an active acct. OCC. is our regulator. What fed guidelines & internal controls would we violate?
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.
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?
12/20/2015
With the new TRID regulations from October 3, now placing lot loans under Regulation Z, in the event of refinancing a lot loan, does the right of rescission apply?