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Credit Sales and Integrated Disclosures

01/03/2016

Prior to Integrated Disclosures, a credit sale (selling and financing an OREO property) required us to disclose the Total Sale Price on an Estimated and Final TIL (12 CFR 1026.18(j)). Is there a similar requirement on the new Loan Estimate and/or Closing Disclosure or has this gone by the wayside?

TRID's Services 10% Cumulative Tolerance

12/20/2015

In regards to TRID's services that a consumer is permitted to shop for, if the customer does not select a service provider and requests that the lender choose a service provider for them, is the amount charged subject to the 10% cumulative tolerance?

Tolerance Categories for New TRID Rules

11/15/2015

I have a question regarding tolerance categories once the TRID rules go into effect. Here is my potential scenario: Our customer chooses to purchase Owner's Title Insurance. We do not require​ that they do this as a condition of the loan. What if the company they choose is an affiliate of our company. Would this fall into the no limit or zero tolerance category?

Cash to Close Changing from LE to CloD

11/08/2015

Are there set rules on the Cash to Close changing from the LE to the CloD? For example, borrower requests a cash out refinance. The LE discloses in the Cash to Close section that they will be receiving $50,000. We find out prior to closing they want to pay off a loan and receive the leftover money at closing. So the money to the borrower has drastically been reduced. Are the changes in cash to close regulated by certain guidelines?

Estimated Taxes, Insurance and Assessments on LE

11/01/2015

Regarding the Loan Estimate under Estimated Taxes, Insurance and Assessments​:​ We were told that we had to estimate taxes, insurance including flood and other assessments In order to complete the monthly payment. How are we going to know if they are in a flood zone within 3 days of application with out running a determination? I would like to not incur that expense until we get back the intent to proceed.

30 Year Construction to Permanent Loan

08/22/2015

If you are doing a 30 year construction to permanent loan with a 1 year construction period, does it or does it not qualify as a Qualified Mortgage if it meets all other criteria?

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LTV on a Lease Assignment

11/24/2024

When securing a loan with an assignment of leases and rents, how much could be advanced compared to value of the lease assignment? Is there any "standard" which is acceptable?

Applications, Reg B, Fair Lending

11/24/2024

Can you remove the primary borrower off a pending loan? I was under the impression that as long as both borrowers were married, and they both completed the application and received the initial disclosures that the primary borrower could be removed and the co-borrower moved over to the primary borrower position. This was the only way, and any other attempt would result in a denial, or withdrawn application. We have done this with a couple of our loans, but upper management wanted documentation stating that this can be done.

Advertising, IRS tax forms, Privacy, RESPA

11/24/2024

Our marketing department brought up the idea of handing out $50 coupons to our customers to entice them to refer folks to get a mortgage loan with the bank. The idea is that if a customer refers someone for a mortgage loan and it closes, the customer can redeem the $50 coupon for cash. I reviewed 1026.36 but it only seems to cover MLO compensation. RESPA's 1024.14(b) seems most applicable but i'm not sure if that just pertains to the parties involved in the transaction. This would be a referral for our customer who told someone to get a mortgage with us. Are there any regulations on a $50 referral ‘bonus/compensation’ to our customer for referring someone to one of our MLO’s to close a mortgage? It seems similar to what the big banks do with something like a $200 bonus to open an account with them.

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