The rules that are effective July 30,2009, do they apply to fixed rate loans also and only to high priced loans (Section 32 loans)? The more I read the more confused I get!
Maybe this recap will help
July 30 - Is a Change, or Modification to portions of Reg Z
So they apply if Reg Z applies (Fixed or ARM doesn't matter)
- - Requires wording in early TIL - essentially saying you are not required to get the loan just because you received disclosures
- - Requires early disclosure in more situations (Refi ; Jr. Lien - Home Improv, Home Equity ; Second Home ; Vacation Home ...)
- - Matches up with RESPA - Can't charge a fee, other than for Credit Report, before early disclosure given
- - Adds 7 Business Day "Cooling Off" period (my terminology) from disclosure to the first day the loan can close
- - Requires Re-disclosure of TIL if the APR on early TIL becomes Out Of Tolerance
- - Adds 3 more Bus days from Re-disclosure before you can close AND another 3 days to make sure the applicant Receives the disclosure if mailed
In October it Adds To Reg Z (Changes to HMDA Rate Spread - so that these match up)
So they apply if the loan fits into this category
- - Creating a new category of loans between "Normal" and "Sec 32 - HOEPA" = The new HPML & part of this is rate spread calculation (different for Fixed and for ARMs)
- - Advertising Requirements
- - Can't coerce appraisers
- - Must Qualify borrowers and Document repayment ability from a 3rd Party Source
I THINK I got it all in there