Most Popular Lending Content
Disclosing title fees on the loan estimate
03/30/2025
For our portfolio mortgage loans we disclose title fees in the section of the loan estimate marked "borrower allowed to shop for" since we do not usually have a detailed fee quote before the loan estimate is required. A closing fee or settlement fee usually charged by the title company is a prepaid finance charge. Should we disclose a Title Closing fee and mark it PPF on the loan estimate even without an exact quote so that we do not have to do a new loan estimate for a changed circumstance due to a change in APR exceeding .125 when fees do come in prior to sending the closing disclosure?
Keeping '1071' small business lending data secure
03/23/2025
I am working on a process to comply with 1071 small business data collection. We have an automated system that will collect and keep the demographic information behind the fire wall. My question is what about the customers who don't use email or technology? Any ideas on how we can collect and keep this information secure? Have you heard what other FIs are doing in this situation?
TRID Purpose for placing manufactured home on land
03/23/2025
What is the correct TRID purpose for placing a manufactured (double-wide) home on land that is owned free and clear? The loan was closed with the purpose of combining the value of a new factory built manufactured home and the value of the land on which it was located immediately after closing. In order to assure the manufactured home dealer would deliver and set up the home on the land timely, the dealer was paid in three disbursements from the borrower’s proceeds which were held until a final inspection was completed. The loan was not closed as temporary financing, but to purchase the home and place it on land. We used “Home Equity” on the Closing Disclosure, but we are being questioned as to why we did not use “Construction” since we made three disbursements from the proceeds. They were not true “advances” from the principal of the loan, but rather three disbursements from the borrower’s proceeds. We close two separate loans for true construction loans for homes built from the ground up; one being 12 months interest only and the other being a refinance of the construction loan for permanent financing. We have offered combination manufactured home and land loans for many years and have not been cited for our handling of the TRID purpose until now. I think the auditor was triggered by the use of the terms “advance” and “undisbursed loan funds” on the Closing Disclosure to show the amount paid to the dealer at closing and the amount we were holding. We have since changed our terminology to use “payment” and “funds held.”
Commercial lending and early capture
03/23/2025
Why is early capture beneficial for commercial lending?
Reconsiderations of real estate value
03/23/2025
Has the Reconsideration of Value (ROV) disclosure guidance been signed into law?