07/19/2010
Can we escrow taxes and insurance for commercial property?
07/19/2010
Is a loan on property of twenty-five acres or more exempt from MDIA requirements?
07/12/2010
YSP was not considered APR impacting prior to RESPA Reform (built into the rate). With the change on the GFE to reflect YSP as a credit to the borrower, is this now APR impacting? We think is should be treated the same way it was prior to RESPA reform, but are concerned RESPAs change may have an unintended impact on Regulation Z.
07/05/2010
When issuing a revised GFE, is the original date of the GFE maintained even with the revised GFE?
07/05/2010
In the 4.26.10 issue of the Weekly Banker Briefing, guru Randy Carey answered the question about appraisal fees (which itself does not apply to our operations) and ended with, "There is no longer a required provider list required to be given to the applicant." I am unclear on the reference. We do not allow shopping for the appraisal, but we do allow it for one item we require. What is the specific reference?
06/14/2010
We have customers who come into the bank and apply for a construction loan. This construction loan will be paid off by the bank's mortgage company. The bank's mortgage company is a part of the bank, but those loans are sold so documents are prepared by our mortgage company for the permanent financing. Is our twelve month construction loan covered by RESPA? Again, these will be handled as two separate loan transactions, one being the construction loan phase and then the second being the permanent financing.
05/31/2010
Is the new HUD settlement statement to be used in all real estate transactions, or only RESPA-related transactions with a GFE?
05/24/2010
Regarding the new changes that went into effect 1-1-2010, the one that I am having an issue with is the charges that are supposed to be listed on the new GFE. I told my boss that all charges that are related to a residential one to four family real estate loan, have to be listed on the GFE whether or not we are going to actually charge them. He states there is no reason why if we know up front that we are going to charge one of the fees, why we should have to list it on the GFE. I told him that the new changes state that we have to do this, so I have to have prove where the reg actually states this. He said he isn't going to go by someone's opinion of the reg (such as from a seminar/webinar). He wants it straight from the reg, so am I correct in stating this? If so, please provide me the reg that states this and the explanation.
05/17/2010
Regarding temporary financing or a bridge loan, it looks like RESPA does not apply but what about TILA?
05/03/2010
Is an Early Truth in Lending disclosure required on an owner occupied one-to-four family purchase that includes over twenty-five acres of property?