04/26/2010
If we have a ten year loan (amortized over twenty years) with a balloon payment due at maturity, do we use the variable APOR tables, or fixed APOR tables to determine if we have a high priced mortgage loan?
03/22/2010
For companies that do not use a lock date, would using the application date work for the lock date when it has been determined that HPML loans will not be made?
03/01/2010
Can maturing balloon loans secured by a primary residence be modified to change the rate and maturity date, with no fee charged to avoid a higher priced mortgage loan category? There would not be a new contract for a renewal or refinance. Do new TIL disclosures have to be given if the rate and maturity date change? On the same type of loan, can we simply extend the due date for another 36 or 60 month balloon, and change nothing else on the note to avoid HPML status?
02/22/2010
Can maturing balloon loans secured by a primary residence be modified to change the rate and maturity date, with no fee charged to avoid a higher priced mortgage loan category? There would not be a new contract for a renewal or refinance. Do new TIL disclosures have to be given if the rate and maturity date change? On the same type of loan, can we simply extend the due date for another 36 or 60 month balloon, and change nothing else on the note to avoid HPML status?
02/08/2010
What is the lock in date on an APR for the new HPML? Is it the date the loan is approved or is the date of the final TIL disclosures (closing documents)?
01/25/2010
If a HPML loan is made today, before the requirement to escrow takes effect, does it need to have an escrow created once the 4/1/10 deadline comes?
01/25/2010
Regarding the new Reg Z amendment that added section 35 for HPMLs, are one-time close construction loans that have interest only payments during construction and then convert to permanent financing upon completion, subject to the HPML requirements?
01/25/2010
Is a loan modification subject to the higher priced mortgage loan restrictions under Truth in Lending?
01/11/2010
We are making a mobile home only loan (no real estate). We understand that no early disclosures are needed (TIL, Good Faith, Etc.) when RESPA does not apply, so does this also means that the seven day waiting period does not apply with this loan? This is a purchase of a mobile home. Section 35 (HPML) mentions that any principal residence can fall into the HPML category. Is this correct? Do we have to check our APR against the APOR to see if this is a HPML even though we have no real estate?
01/11/2010
When we are doing a modification to a five year balloon, do we have to take into consideration the repayment ability for Higher Priced Mortgages?