Most Popular Lending Content
Integrated disclosures, Pol/Proc, Reg Z
06/30/2024
If our policy is to not disclose Title Insurance on loans less than $300,000, could a Change in Circumstances such as an error allow us toredisclose with title insurance, if this can be done within 3 days of being notified of the error? If so, would this cause the closing date to be moved further out?
Explaining discount points on mortgage loans
06/30/2024
If I am making an informational post about what mortgage points are and I state, "Each point typically costs 1% of your total loan amount and can reduce your interest rate by a fraction (usually 0.25%)," is that technically a method of determining a finance charge and subject to additionaldisclosures per section 1026.16? I should note that this post is an explanation of what discount points are, and not necessarily an advertisement for a specific product, but also I'm not sure there are carveouts from the provision. Any help would be greatly appreciated. Thank you!
Right to rescind on future advances loan
06/23/2024
I have a question regarding the right of rescission. On a future advance loan, does the right to rescind apply? The original loan was for $75,000 and secured by their the borrower's principal dwelling. They've paid the note down to $35,000. The new note is a future advance on their property and the note will be for $35,000. I think the right to rescind should apply since it is a new advance, even though the total loan amount is less than the original loan amount. I'm new to compliance and we do not do many future advance loans. We are in Missouri, if that matters.
Bulk sales value in commercial real estate transaction
06/23/2024
When is a bulk sale value required in a commercial real estate (multifamily rentals) transaction according to the OCC?
HMDA reporting of business loans
06/23/2024
I thought business purpose loans were exempt from HMDA reporting.