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Latest Lending - Integrated Disclosures Topics

Recording Fees on the TRID Closing Disclosure

08/25/2024

I have discovered that the Other Costs section of our Closing Disclosure does not list the mortgage release fee of $27 in the details, but it is included in the total amount of Taxes and Other Government Fees. I was told that it can be seen in nCompass, but doesn't pull over to the Closing Disclosure. Is the description of each fee required to be listed under the Other Costs section of the Closing Disclosure?

Loan estimates and referrals to subsidiary insurance

08/25/2024

We are in the process of implementing an insurance agency subsidiary owned 100% by the bank. We will not be quoting the agency’s rates on LEs or listing the insurance agency on the Services You Can Shop for Disclosure. However, our lenders will be referring mortgage loan customers to the insurance agency, so my understanding is the referral is what triggers the Affiliated Business Arrangement Disclosure requirement. So we are trying to figure that out. My question is, how should we provide an estimated range of charges for insurance? That could be vastly different depending on the home, location, etc. Any guidance would be greatly appreciated!

Notifying borrower of an increased appraisal fee

07/07/2024

I am sending a revised Loan Estimate for an appraisal fee increase. What verbiage do I use to justify that the appraisal transfer invoice shows the fee is now $575 versus the $430 which was initially disclosed. This is an appraisal transfer from another lender., and I am not sure what the correct verbiage would be for this change.

Integrated disclosures, Pol/Proc, Reg Z

06/30/2024

If our policy is to not disclose Title Insurance on loans less than $300,000, could a Change in Circumstances such as an error allow us toredisclose with title insurance, if this can be done within 3 days of being notified of the error? If so, would this cause the closing date to be moved further out?

Disclosures and Acquisitions

06/25/2023

We received a mortgage loan application and sent out the initial disclosures. During the loan process the loan officers mortgage company was acquired by another. Does this require a new loan or can we just update the company name and NMLS so it is correct on our loan documents (the Note and Deed of Trust)?

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HMDA reporting and loan purpose

11/17/2024

If we have a consumer HELOC denial with the stated purpose of "purchase land to build a gas station," is it HMDA reportable?

HELOC historical table and SOFR

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?

Administrative loan renewals and interest rate change

11/10/2024

I continue to get push back from our lenders to change rates when we have Administrative Renewals. Reason for an Admin Renewal may be that the customer does not have a current Tax Return or Personal Financial Statement. Our current practice, when doing an Admin Renewal, is to only extend the maturity date by 90 day and make NO other changes. Is anyone else making rate changes at the time of Admin Renewals or doing them for longer than 90? Is this a regulatory issue with commercial and/or consumer loans and if so, what regulation would we be violating?

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