11/17/2024
Reg Z section 1026.40 requires us to disclose a historical table to reflect the most recent 15 years of index values. However, SOFR has only been available since 2018. Do we only need to disclose the years starting from 2018 even when the length of the plan is more than 15 years?
11/10/2024
How can a HELOC be reopened when closed erroneously without the member having to reapply for financing?
09/17/2023
Can you do a HELOC on a home a customer is buying? The first draw will be to complete the purchase.
The house has a purchase price of $90,000 and they need to borrow $30,000. They don't want all the expenses and hassle a regular mortgage entails. They want to just take out a HELOC on that new home. A HELOC is not TRID so we would not need all the documention either.
06/18/2023
We have a home equity application disclosure that has a lower Annual Percentage Rate stated than it should be. The disclosures shows in error 4.0% in the minimum payment requirements paragraph where it should be 8.25%.
Is this something that we can fix or is this a rate we must now live with?
05/14/2023
On Home Equity Line of Credit statements, is it required or acceptable to include the FDIC and Equal Housing Lender logos for notices and statements?
05/07/2023
I am looking for some clarification on disclosing the finance charges section which states the components of the finance charge shall be individually itemized and identified to show the amount(s). Start up fees - charges are financed as part of the plan, including charges that are paid out of the first advance, charges must be disclosed.
My question is, we have a HELOC that financed all fees into the loan. Our operations department was told to list them individually. However, they combined the Recording and E-Recording fee as a single total, with the description of Recording Fees. Then the Title Insurance fee and Title Services fee were shown as a combined total with the description, Title Insurance Fee. Would this suffice or should they truly be separated out? My recommendation was to list them all out, to mitigate confusion but our operations team is unsure if we can add the additional fee modifiers to our banking system.
04/23/2023
Are there best practices for handling loans with two borrowers and then one passes awayY What is the best way to handle consumer and mortgage loans when this happens? Should the bank require the survivor to refinance or allow them to make regular payments?
And what about HELOCS? Would it be best to remove the limit and allow payments on the balance, leave limit and allow terms of HELOC to continue or require them to requalify/refinance?
Then, what about IRS reporting if the decease person's SSN is on the 1098?
02/26/2023
Here is the loan scenario: We have a HELOC for $100,000. Collateral on the loan is rental property. The loan purpose is for home improvement. Our borrower stated that funds will be used as follows:
- $50,000 to do home improvement on rental property, and
- $50,000 will be used for home improvement on their primary residence.
Would this HELOC be considered primarily for business or commercial purposes and why?
10/23/2022
Can we advance funds after flood expires?
09/25/2022
Our HELOCs are variable rate, but don’t have an “introductory rate." The rate is just subject to change on the first business day of every month. Is that reported on the LAR or do we just put NA since we don’t technically have an introductory rate?
Additionally, if we require in the loan contract that the borrower reimburse fees we as the lender paid if the loan is paid off in the first 36 months, does that number need to go under Prepayment Penalty term if we aren’t technically charging a “prepayment penalty”?