12/31/2023
The initial and locked Loan Estimate (LE) on an ARM loan was based off the WSJP index. When it was time to issue the initial Closing Disclosure (CD), the WSJP index had increased causing the APR on the CD to be about 1/2% higher than on the last LE. Should we adjust the index value on the CD to match the index value used on the LE to keep the APR within tolerance, or do we need to update the index value to the current value and redisclose the LE and then inssue an initial CD?
09/17/2023
Can you do a HELOC on a home a customer is buying? The first draw will be to complete the purchase.
The house has a purchase price of $90,000 and they need to borrow $30,000. They don't want all the expenses and hassle a regular mortgage entails. They want to just take out a HELOC on that new home. A HELOC is not TRID so we would not need all the documention either.
05/28/2023
This is for a TRID - Lot/Land loan. Is an Irregular payment schedule with 12 months interest only payments followed by a payout term (ex. 24 months P&I with 108 months amortization, and any balloon) allowed?
03/19/2023
On the loan estimate, I input it as a balloon rather than installment which drastically increased the payment. Do I need to redisclose theis with a revised LE or do I make the correction in the closing disclosure?
01/01/2023
TRID Closing Disclosure confusion on Seller-Paid H, Other, and J, Total Closing Costs Subtotals (D+I) – Should we disclose all fee/costs listed on our Title(Seller) CD?
According to 1026.38(h)(2), it appears that we should list ALL loan costs on page 2 of the closing CD under section H. Also, 1026.38(k) discusses Summary of seller’s transaction.
For example, we had a Judgement Payoff to a Law Firm ($987.97) in section H of Seller-Paid on our Title CD. This was not disclosed on our Buyer’s CD and does not carry over to section Seller-Paid – Section J. Total Closing Costs Subtotals.
My concern is that the totals do not match the Title-CD bottom line “J-Closing Costs Subtotals.” What is the correct way to itemize and disclose these?
12/25/2022
We have a builder in one of our markets who is the seller on one of our transactions. He wants to pay to buydown for the borrowers interest rate. This would cause us to go over the points and fees threshold. My question is, would a seller paid amount to take the rate down be exempt from the points and fees calculation?
11/20/2022
May a seller’s statement be provided by the title company in lieu of a seller’s closing disclosure? It contains all of the same information as provided in Model form H-25(I) in Reg Z. (https://www.consumerfinance.gov/rul...e7023baceb466835a39ca4fa95107c1f1037ca3c)
This is a purchased loan and we are performing quality control checks on a file.
11/13/2022
I have a borrower who would like to use his primary residence as collateral for a business line of credit in the business' name. Does TRID apply or any other regulations if its a business purpose?
09/18/2022
Do all seller paid fees have to be shown on the borrower's closing disclosure (CD)? For example, if the inspection reveals an issue with plumbing and the seller agrees to pay for a plumber, does that amount need to be placed on the borrower CD?
09/18/2022
Do you need to document the credit file giving the reason if the application loan amount changed compared to the closing table amount, whether it is a consumer, commercial, or residential loan application?