02/27/2006
We have been cited during a recent FDIC compliance exam for not including POC costs for hazard insurance and property taxes on the form HUD-1A, when the customer obtains a second-lien home equity type loan. We have never been written up for this before and the fees don't seem to fit in the categories provided on the HUD-1A. Are they really required to be listed?
02/13/2006
When selecting the "action taken" for a HMDA reportable loan, we're in a debate, when a loan application has received conditional approval, meaning the credit approval has been done by using the credit history, debt ratios, etc., but the customer does not provide proof of insurance for the residence being taken as collateral. The loan doesn't go to closing. Do we consider this "approved not taken", as the additional "conditions" we are waiting to have satisfied are similar to those described in Appendix I - Staff Commentary? i.e. "Action taken—conditional approvals". If an institution issues a loan approval, subject to the applicant's meeting underwriting conditions, (other than customary loan commitment or loan-closing conditions, such as a clear-title requirement or an acceptable property survey) and the applicant does not meet them, the institution reports them action taken as a denial.
11/21/2005
Second mortgage Installment loan. We are requiring they have hazard insurance. It is paid out of closing. Does this affect APR for the truth in lending document?
09/19/2005
When disclosing hazard insurance as "p.o.c." on the Good Faith Estimate, does it matter where the dollar amount of the premium is listed? We currently disclose 0.00 in the amount column and include the premium amount immediately to the right of "p.o.c." We are in the midst of implementing an on line application that includes on line disclosures. The vendor of this product includes the dollar amount of the premium in the amount column on the Good Faith Estimate. Since this is different from what we've been doing, we are trying to determine if this is acceptable under RESPA. There doesn't seem to be anything that specific in RESPA regarding completion of the GFE, just disclose as "p.o.c."
09/01/2005
Have you ever gone back and looked at a law or regulation when it was just adopted and then compared it to today's version? Take CRA for example.
08/15/2005
Do we have to disclose the exact amount of hazard insurance on the Settlement Statement whether or not it is disclosed as a POC item or an actual settlement charge?
07/01/2005
07/01/2005
Just in case anyone had doubts, regulatory burden is real. In fact, the banking industry has dealt with an average of 50 new or amended rules every year for the past ten years.
04/04/2005
What formula do most bankers use to calculate the amount of hazard insurance required on a loan (this isn't for flood insurance)?
12/01/2004
Since their invention or evolution, banks have been designed for protection and security. Those who manage financial institutions are protectors.