06/13/2011
Reg Z - I have a borrower who is using his mother's primary residence as collateral for consumer purpose. The mother is not going to be on the note itself. She is just pledging the collateral. Would the Higher Price Mortgage requirements apply and is an Escrow required?
06/13/2011
When we have a Commercial Loan we do not require a application. If we are use a personal guaranty do we need to use a consumer application or do we need a special commercial application?
04/11/2011
If a loan officer doesn't disclose a survey fee to the buyer on the GFE (even though contract shows buyer will be party to pay for this) and we require the survey deletion in our title policy, are we required to pay for that fee at closing? This was not disclosed on GFE and the borrower did NOT pick a surveyor on our shoppable providers list.
03/21/2011
Does the Initial Escrow Account Disclosure Statement need to be provided yearly along with the Escrow Addendum?
01/17/2011
What is FASB91 and are all financial instatutions required to follow it.
01/17/2011
We are doing the construction phase of a construction to permanent loan. The loan will move into payments without a modification. It will require escrow. When do I give the initial escrow disclosure? Do I collect the escrow payment during the construction phase which is interest only?
12/06/2010
My borrower was disclosed an adjustable rate loan by a former loan officer. I changed the program. Is this considered a change in circumstance?
10/18/2010
We have a corporation/LLC that is the borrower and individuals signing guaranty agreements. Do the guarantors have to sign the statement of intent to apply for joint credit?
10/11/2010
A loan customer has requested that we not send him loan payment notices. Is there a reg against this or is it left up to the discretion of the bank to allow or not allow. We do not want to grant this request, since customers may become delinquent and bank has somewhat agreed to the customer's request to not send loan payment notices.
10/11/2010
We have a refinance loan (paying off a different mortgage, and they are refinancing with us). During the application process, there was a borrower and a co-borrower, but the co-borrower was to be removed because his credit score would have required that the borrower pay points for credit risk. Now, the loan is stated to be just a single applicant loan, but both borrowers are on the signed Deed of Trust (DOT)(Mortgage). They are listed and have signed the Final Truth in Lending and the Final HUD Settlement Statement. The co-borrower's name was still provided at closing and added to the closing documents almost fifteen days after the co-borrower was to be removed. HMDA also reflects the loan to be a single applicant loan. The final application has been signed by both parties, but the co-borrower's name was not disclosed on the final application; the co-borrower just added a signature. In the file, there is only a Right of Rescission (ROR) for the primary borrower, but the file indicates to us there should be a co-borrower also, due to both borrowers being listed and having signed the DOT. The closer failed to remove the co-borrowers information from the final closing documents. There are some documents that only have the primary borrower disclosed. Should there be a ROR for the co-borrower since they are both listed on the DOT and all the final closing documents with both signatures?