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?
01/26/2025
Is the Military Lending Act disclosure required on loan renewals? Does it have an expiration date of when it should be pulled? For example, if the loan was prepared in October, but didn't close until February would I need to pull another MLA status report?
09/02/2018
If a customer is disputing a transfer of funds between accounts on which she is a signer, whether it was done via
online web, mobile phone, ATM, at a branch or over the phone with a banker, does this fall under the Regulation
E guidelines?
03/18/2018
Is a construction only loan to a consumer covered by HMDA when there will be a separate loan for the long term financing??
10/22/2017
Does ROR apply to an Agriculture 1st Mortgage land purchase loan when taking a 2nd mortgage equity lien on the borrower's residence? Borrowers are not full-time farmers and the loan is made to them individually (not a corporation or "business").
06/03/2013
I have a purchase money mortgage with a non-occupant co-signer. Can both parties sign one set of disclosures and one loan application or do we need them to each sign their own set?
02/25/2013
In reference to the SCRA, I understand it applies to obligations obtained prior to a military member entering active duty. If a member was on active duty when they obtained a loan--be it Guard, Reserve or Regular component--separated from the service, then enlisted again or was recalled to active duty after a break in service, would that member qualify for SCRA relief if they were to apply subsequent to the reenlistment or recall?
10/22/2012
For home improvement loans in Texas, does Reg Z apply? Is there a list of requirements somewhere?
10/18/2010
We qualify loan applicants based on gross income. Our credit officer says that tax free income from SSI or VA Disability is the gross income and shouldn't be grossed up. I say the income is net and should be. Who's right? If we don't gross tax SSI up, are we discriminating?
09/13/2010
We have a customer who took a 3/3 ARM four years ago. It adjusted at the three year mark as normal, but then adjusted one year later (last month). When the customer contacted us, we realized that it had been mis-entered in our system as a 3/1. The customer has benefited from a lower rate at this point (first new payment is currently due), but we are not sure of the implications from correcting this. My thoughts are to do one of three things: 1) Allow this payment to be made at the lower rate, but change the product back to the 3/3 at the current (higher) rate for the remainder of the term. 2) Offer to keep the lower rate and do a modification to a 3/1 if the customer accepts. 3) Change the product back to the 3/3, but keep the lower rate for the remainder of the period (2 years) Any thoughts from a compliance or legal standpoint?