05/03/2004
Is it true that effective April 15, 2004, we should provide a separate notice of right to receive a copy of the appraisal? Currently, this notice is on the back of the Good Faith Estimate. Should we be giving separate notices since not every loan will have a GFE?
04/19/2004
I'm in the process of completing an audit of the Fair Housing Act for a national bank. The OCC requires that "each bank shall attempt to obtain all of the information below." It then goes on to require a considerable amount of information in excess of the traditional government monitoring information (race, ethnicity, sex, marital status, and age). Is all of this information required to be on the application? Will the information (such as amount requested, interest rate requested, # of months to maturity, and proposed monthly payment) being in the loan file on some other document suffice? Also, does the fact that the application is partially completed suffice for compliance with the regulation for "attempting to obtain" the information?
03/01/2004
Where can I find rules to determine which items on a Good Faith Estimate are prepaid finance charges?
01/19/2004
What required disclosures to you need on a HELOC ifthe main purpose of the loan is to purchase the borrowers' house? They are only asking for $40,000.00? Do you need an early truth in lending disclosure or early good faith estimate and any other early disclosures?
01/19/2004
If a lender fails to disclose 15 odd days of interest on the Good Faith Estimate (either 10 or none) is a new disclosure required?
02/17/2003
For a residential construction loan where the borrower will eventually occupy the home upon completion, is it necessary to supply preliminary disclosures such as the good faith estimate and truth in lending documents at the time of application?
10/21/2002
I have two questions regarding RESPA issues related to indirect home improvement financing. First, we are paying a broker - who is not an employee of the bank - for signing up contractors to submit credit applications on their customers to us. Since most of these loans are secured by a mortgage on a primary residence and we are paying the broker a percentage of total loan volume generated, how do we treat this with respect to the Good Faith Estimate and HUD-1A? Secondly, since we require hazard insurance coverage from an insurer chosen by the borrower, is it not permissible under RESPA to provide only an estimate of the annual hazard insurance cost on both the GFE and HUD-1A forms? We are being told that the GFE can reflect an estimate, but that the HUD-1A must be the actual annual premium amount being paid by a given borrower. This presents a problem, in that, since the program is indirect, we do not know what the actual premium cost is for any given borrower and , therefore, use an estimated cost amount on both documents. Are we in compliance?
10/17/2002
10/14/2002
Household International's Household Finance Corporation ("Household") has agreed to implement the following new initiatives in its HFC/Beneficial branch based businesses:
10/01/2002