04/14/2003
With the Revised Article 9 would you suggest to continue getting property and legal descriptions for Agricultural or crop loans on state filings and security agreements?
08/19/2002
07/15/2002
The FDIC recently completed a compliance examination at our bank. TheCompliance Report of Examination identified significant violations ofRESPA. In the first violation the bank was cited for not detailing thenames, addresses, and telephone numbers of each lender-designatedservice, [Section 3500.7(e)(1)(iii)] and for not describing the natureof any relationship between each and the bank [Section3500.7(e)(1)(ii). In the second violation, the bank was cited forproviding mortgage servicing disclosure statements that did notdisplay the bank's servicing transfer record for the most recent threecalendar years [Section 3500.21(b)(3)(ii)]. Finally, in the thirdviolation, the bank was cited for having five mortgages that containedGood Faith Estimates and HUD-1 or HUD-1A statements that did notreflect an estimate for hazard insurance.I am new to the compliance arena and I have been assigned the task ofcorrecting these violations. Since these mortgage loans are already onthe books, should the bank issue "correct" Good Faith Estimates,Servicing Disclosure Statements, and HUD-1 or HUD-1A's that reflectestimates for hazard insurance? Or should the bank take note of theviolations and not make any corrections because this problem is akinto "closing the barn door after the horse has already left"? Anyrecommendations that you can offer to correct these violations iswelcomed!
06/17/2002
Our company supplies compliant software to banks.We have several banks who disagree on whether credit life and A&H insurance should be shown on the HUD statements.It is shown on the final TIL in its own section, but from reading HUD instructions, I do not see that it is a requirement.What is your opinion?
04/11/2002
08/06/2001
Can we charge a fee for providing payoff statements on consumer mortgages and if so what disclosure issues exist?
07/09/2001
What can we do to spot a fraudulent financial statement? We have taken some sizable losses due to a customer inflating assets and omitting liabilities.
05/07/2001
I am a mortgage broker. Certain local banks and credit unions want to refer loans to me. ...I could swear there used to be a RESPA checklist that outlined the things a person had to do in order to earn a fee, and of this list you had to do, I think, 5 of the entire list in order to legally earn a fee.
05/01/2001
- The average credit cardholder's outstanding balance is $4,400 - up 123% over what it was in 1991. During the same period, personal income rose 72%.
02/05/2001
Can I get a clarification on the filing requirements under the new Article 9 for a continuation. I was under the impression that if a continuation was filed PRIOR to the July 1st effective date that it would be filed in accordance with the current Article 9 rules and thatit would be effective. Basically, do we have to file an "in lieu of" financing statement prior to the effective date or do we file the same way we have in the past?