10/18/2010
If the loan purpose is for personal use, and the collateral is rental property that the borrower does not live in, do RESPA and Reg Z apply?
10/18/2010
The bank wants to give a gift under $25 for all customers who fill out applications for credit cards or loans. This promotion will be held at branches in certain areas, but not statewide. Flyers will be available at all the personal bankers' desks. What would be the compliance requirement?
10/11/2010
Was there a requirement to provide preliminary Truth-in-Lending disclosures on owner occupied refinances prior to 8-1-09? If so, can you cite the reg so that I can reference it?
10/11/2010
Relative to Reg Z, is a financial institution considered a mortgage broker?
10/04/2010
Manufactured housing loans where the MH is permanently attached to real estate per FHA guidelines and where the MH titles have been vacated - these loans clearly are subject to RESPA. The lender is secured by a real estate mortgage as the MH is considered as being a part of the real property and is no longer personal property. Here is where some confusion lies: RESPA appears to be clear that MH loans are exempt unless the MH has been permanently affixed to the real estate, so what is the definition of permanently affixed? It used to be that for a MH to be considered as being permanently affixed to real estate, the MH had to be set up per FHA’s foundation requirements, tong, axles, etc., removed and titles vacated by the state. However, there is confusion in cases where a lender finances a manufactured home that has titles, is not affixed to the real estate per FHA permanent foundation requirements, but is simply set up per local requirements and where the lender takes a mortgage on the land where the MH is placed. A MH with land does not mean that the MH is permanently attached to the real estate, so the heart of the question is simple: if a lender takes a lien on a MH and also takes a mortgage (as additional collateral) on real estate where the MH is located, but not permanently affixed, is this covered by RESPA or not?
09/20/2010
Where do we put the fee for tax return verification service (4506T) on the GFE and HUD? Is this fee a prepaid finance charge?
09/13/2010
On a RESPA applicable loan, can I check the cross collateralized box on the Deed of Trust just as general practice, or will this create a compliance issue?
09/06/2010
For the Written List of Providers as required by RESPA, do the fees or range of fees have to be disclosed on this document? Also, does the document have to be exactly like the model form in Appendix D?
08/30/2010
Our bank did a construction loan for a customer knowing that permanent financing would be done when home was completed. RESPA documents were given to customer when construction loan was done(preliminary disclosures, TIL, Good Faith etc). Now we are closing the permanent financing loan. Is there Right of Rescission on the permanent financing loan?
07/26/2010
Does a primary residence mobile home loan with no land, fall under RESPA and Reg Z? We are getting conflicting information.