06/21/2010
Under the new HPML regs (226.35), escrow of taxes and insurance is only required if you are "extending a loan". If we are doing a rate modification on an existing loan, HPML calculations do not apply. Is this correct?
06/21/2010
If we have a Section 35 high cost loan, and we are taking additional vacant land as collateral, do we have to escrow for the property taxes on the vacant land in addition to the taxes and insurance on the home itself?
06/21/2010
Under the new HPML rules, most of our loans will be required to have the customer escrow for taxes, insurance, etc., for a minimum of twelve months. We handle mobile homes, and many times customers will pay their homeowner's insurance premium prior to closing for two to three years in advance. Practically all of these customers would seek to cancel their escrow requirements after the first twelve months has been reached. If this were to be the case, would an escrow account need to be established for the insurance portion, since they already paid the premiums?
06/14/2010
Are HPML second loans allowable at all and if so, what rules apply?
06/07/2010
Do the higher-priced mortgages apply to first lien residential property that will be used for rental, not primary residence?
05/31/2010
We have an application for a temporary (less than twelve months) home improvement loan to be secured by the principal dwelling. This loan will be done as a multiple advance, closed-end loan, while the project is being completed. Once the project is completed, this loan will be re-written into a term loan. Is the temporary loan exempt from the HPML requirements? Is it considered a "temporary loan" for this purpose?
05/31/2010
Because of the HPML escrow requirements, our bank is just getting started with escrow. Do you have any advice for procedures and getting the system in place?
05/24/2010
After 4/1/10, if a loan is considered a first-lien HPML for purposes of Reg Z, does the escrow requirement still exist if the property contains more than twenty-five acres? Since RESPA exempts properties of twenty-five acres and greater, and also covers the escrow rules, is this a valid exemption for HPMLs as far as escrows are concerned?
05/17/2010
We have several loans that have an advance clause as a part of them. If the loan is an HPML, could we amend the loan without re-writing and avoid the escrow issue? The terms and condition would remain the same. The payment would change. Would we have to escrow the amount of the advance if the loan is not re-written?
04/26/2010
We have a business purpose term loan on a residential property that is being assumed by a new buyer (the tenant). We see that assumptions are HMDA reportable, but do we need to be concerned about the HOEPA spread, suggesting that this is a high priced mortgage?