12/16/2002
Is there a section in the regulation that clearly defines what loans are excluded under HOEPA (i.e., construction) Under state regulation it appears that construction loans are exempt however I am unable to locate anything in the reg.
04/01/2002
On occasion, we have had customers who want to substitute collateral (such as wanting to sell the car that is being held as collateral and substitute with another car of same or greater value). We use a substitution form which is signed by the customer. I'm questioning if that is enough. Should the customer sign a new security agreement? Also, we have a difference of opinion when it comes to filing the new lien. Some people use the date of the collateral substitution as the security agreement date and some use the original security agreement date. If the latter is used, what about the 20 days to perfect our lien?