Latest Lending - Dodd-Frank Act Topics

Dodd Frank- Borrower "Shopping for Services"

08/26/2018

I have a lender telling me that the borrower was considered to have shopped for services because the provider listed on the Settlement Service Provider List (SSPL) has 3 office locations and the borrower went through a different office location than that disclosed on the SSPL. The lender believes going to a different office address is considered "shopping." I don't agree, but would like clarification on this.

Fee for Future Mortgage Releases-County Clerk

01/31/2016

Our bank collects a fee for future mortgage releases. Even though at closing the fee goes to us, eventually it is paid to the county clerk when we release the mortgage. For the purpose of the Loan Estimate and the Closing Disclosure is this fee considered paid to the Lender or to the County Clerk? Either way it would still be a 10% Tolerance category correct? If it is paid to the lender would that mean it needs to be included in the finance charge that affects the APR for calculating HOEPA?

Credit Sales and Integrated Disclosures

01/03/2016

Prior to Integrated Disclosures, a credit sale (selling and financing an OREO property) required us to disclose the Total Sale Price on an Estimated and Final TIL (12 CFR 1026.18(j)). Is there a similar requirement on the new Loan Estimate and/or Closing Disclosure or has this gone by the wayside?

Condo Questionnaire Fee- New TRID Rule

12/27/2015

Under the new TRID rule, where would a Condo Questionnaire Fee be disclosed on the Loan Estimate? The questionnaire is required for the transaction but some condos may or may not charge such fee.

New TRID Regs Placing Lot Loans under Reg Z

12/20/2015

With the new TRID regulations from October 3, now placing lot loans under Regulation Z, in the event of refinancing a lot loan, does the right of rescission apply?

Issue Loan Estimate on Same Date as CLoD?

12/12/2015

In order to expedite closing, can the Loan Estimate be issued on the same date as the CLoD?

Seller Paying Pest and Warranty: Disclosure?

12/06/2015

We have a purchase contract that lists the seller paying both pest and warranty, are these disclosable?

Revised GFE Changed Circumstance: Rate Change

11/29/2015

We had a customer apply for a loan secured by their primary dwelling. The rate was locked at 3.75%. The revised GFE was issued stating the rate at 3.875%. Correct rate is 3.75%. Is this considered a changed circumstance?

Disclosure of Prepaid Property Taxes

11/29/2015

Is the disclosure of prepaid property taxes required on both the LE and CloD only if a creditor requires that this be prepaid?

How to Handle Escrows for Repairs on LE & CD

11/22/2015

How do we handle escrows for repairs on the LE and on the CD when we hold them and when the title company holds them?

Loan Solicitation Disclosures Needed?

01/12/2025

Currently our Cascade Alerts only provide that a customer did an application for a Mortgage or Home Equity at another bank, but does not provide any details as to what they applied for. If we were to utilize an option with Cascade Alerts on our Mortgage and Home Equity customers where we would be able to know what type of loan the customer applied for at another bank (Mortgage or Home Equity), what would we then be required to provide disclosure wise to the customer?

Postponing a new loan at borrower's request

01/12/2025

I have a customer application for a home loan to be used for home improvements. We have run the credit report and approved the application, and she has signed the intent to proceed. We just got back the appraisal. Now, she has says that her contractor may be 5-6 months away from beginning her project and she wants to wait until then to do the loan. Am I able to let this sit that long? How long can we sit on this same application? I've never had something like this happen before.

Latest Lending - Dodd-Frank Act Topics

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