Latest Lending - Mail Topics

Waiting Period to Close from Date of GFE

04/22/2013

Is there a specific waiting period to close from the date of the GFE?

HELOC Waiting Period Restrictions (Reg Z)

09/10/2012

Is a HELOC subject to any of the waiting period restrictions imposed by reg Z as of 7/2009?

APR Greater than Tolerance of 1/8-Disclosures

07/30/2012

If the APR change is greater than the tolerance of 1/8, how long do we have to send out the redisclosures to the customer?

REG Z-Periodic Statement for HELOC

06/11/2012

Is a HELOC that is not tied to a credit card or overdraft account, that is a fixed rate with fixed monthly payments required to have a periodic statement monthly?

Early Disclosures Given Same Date as App

06/11/2012

If we give the early TIL the same date as the application, how soon can the loan be closed?

HMDA App by Mail w/o Govt Monitoring Information

06/04/2012

For HMDA purposes, when an application is received by mail and the applicant selects that they do not wish to provide the government monitoring information but still answer the questions of ethnicity, sex and race should the bank complete HMDA as the information has not been provided or complete those questions with the race ethnicity and sex provided by the applicant? There are a few different opinions being given.

Incomplete App & Reg B Adverse Action Notices

05/28/2012

I was asked by a peer about "mortgage bot" application entered on the Internet that were not submitted and not complete to meet the 5 criteria to be a mortgage application (SS#, name, address, loan number and product). I was asked if they require a Reg B adverse action notice. I view them as an incomplete application which technically wasn't even submitted and not Reg B compliant. Am I right these are not applications and do not fall under the Reg B requirement of adverse action notices? They do not fall under HMDA requirements and I do not believe they should be reg B required either. If I didn't have a name or an address I couldn't mail them out even if I wanted to.

"I Do Not Wish to Provide"- Complete the GMI?

05/21/2012

Do we need to complete the government monitoring information on the mortgage application taken over the phone or submitted by mail when the borrower has selected "I do not wish to provide"? If yes, do we use surname to make the choice?

Disperse Loan on 4th Day of Rescission Period?

04/16/2012

Are we required to disburse a loan on the 4th day of the Rescission period? We have some lenders believing they can disburse the loan any time after the 4th day. As a result, I have run into problems such as when to date the loan on the system and what action taken date to use for HMDA reporting.

Do All Signers Need to Sign Pledge Agreement?

01/09/2012

When a savings account is pledged as collateral, do all signers need to sign the pledge agreement or is only one needed?

Booking customer information for disregarded entitities

12/22/2024

We are in a Syndicated Deal (shared national credit) where the loan parties are all disregarded entities to an ultimate parent. The lead bank offered W9s but they showed the tax ID of the parent. The original closing docs consisted of a Perfection Certificate, which showed independent EINs, however two "borrowers" did not. For disregarded entities and for loan only relationships, can the CIFs be booked with the same tax IDs?

Latest Lending - Mail Topics

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