05/19/2014
For owner-occupied loans that are up for balloon renewal (mostly 5 year balloons), are they grandfathered into the Dodd-Frank regs? We are a small creditor and are coming up against some of our renewals not meeting our internal d/i limits since we do not have to meet the 43% rule. Are we still able to make these renewals, or should we have the borrowers move the loan?
05/19/2014
If I have an application for a loan to be secured by rental property (non-owner occupied), does Reg Z apply?
05/19/2014
Is the List of Homeownership Counseling Organizations exempt on a homestead loan on property of 25 acres or more?
05/19/2014
Customer owns 2 acres of bare land. Our loan is to purchase a mobile home to place on this land to be their principal residence. Our system says that ROR applies but our LOs seem to think different. Is ROR exempt on loans of this nature?
05/19/2014
My bank never prepared early disclosures for a non-owner occupied home equity in the past. About a month ago someone said we should be making those disclosures, so we have started. My question is: Do we really have to send out early disclosures for a loan being backed by a non-owner occupied home?
04/28/2014
If loan has a maturing 5 year balloon feature, is going to be given 5 more years and we are past the maturity date, if we print new documents but keep same loan number is this considered a renewal or refinance?
04/28/2014
We had a system glitch that improperly coded the accrual basis. It should have been coded as 365/actual but was instead coded as 360. These are consumer customers. Of course we are going to correct the accrual basis and credit the account for the overcharged amount. Do we need to do anything else re contacting the consumers? Is this found in Z anywhere?
04/28/2014
When the bank imposes 25% penalty rate for 60+ days past due credit card accounts, do they need to send 45-days advance notices to delinquent card holders before imposing penalty rate?
04/21/2014
Is the Right of Rescission required when refinancing a real estate loan secured by 160 acre farm, and advancing funds to pay off credit card debt once loan originated?
02/10/2014
Is No Down Payment in advertising a consumer mortgage on my bank's website a TILA triggering term?