Latest Lending - Reg. Z Topics

Are FHA and VA Loans Exempt from ATR?

02/03/2014

We offer FHA and VA loans. Are they exempt from ATR? Under 1026.43(a)(3)(iv): (iv) An extension of credit made pursuant to a program administered by a Housing Finance Agency, as defined under 24 CFR 266.5; I am not clear whether VA and FHA meet the definition.

Exclude Tax Service Fee/Flood if 3rd Party?

01/27/2014

Can Tax service fee and LOL Flood be excluded if paid to a 3rd party?

Disclose TIL if Loan to Natural Person and Trust?

01/20/2014

We have a loan to construct a primary residence to two individuals and their trust. The two individuals are also the beneficiaries of the trust that is liable. The land is owned by the trust. Since the loan is to a natural person and a trust should a TIL be disclosed?

Points/Fees Calculation Under HOEPA & QM Rules

12/16/2013

Our Bank has an affiliate insurance company. Should any portion of the premiums for flood or hazard insurance be included in the points and fees calculation under the HOEPA and QM rules? Specifically, we would be concerned with those premiums required to be escrowed under 1026.32(b)(1)(iii).

Add What Items to Origination Fee for APR?

11/25/2013

What items are required to be added to the origination fee that affects the APR in a residential 1-4 real estate loan?

Threads About the Lending Compliance Changes

11/10/2009