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Reducing Loan Fees For Employees Only

09/02/2002

Our bank is considering providing an employee benefit which would reduce the closing fees when they finance a new home purchase or refinance their existing first mortgage. In particular, we are questioning whether the bank can pay for the outside costs such as attorney costs for title search and title insurance, appraisal fees, and etc. (for employees only) without violating any regulations.

Finance Charge Violations

10/01/2001

In a R/E transaction (construction loan) if the APR is understated and the finance charge is overstated (due to improperly calculating the estimated interest on the entire balance method) is the violation reimbursable? In reviewing 226.18 and 226.22 it appears that if the finance charge disclosed is greater than the amount required to be disclosed then it is considered accurate and no reimbursement is required. Is this correct?

Is Reimbursement Required?

01/15/2001

Concerning Reg Z and the TIL form, when we find that our bank has improperly disclosed the APR and Finance charge on a mortgage loan, how do we go about calculating the reimbursement? Does this always automatically trigger a reimbursement? I have tried to find info on it in the regulation but have not found anything to help.

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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 This was the only way, and any other attempt would result in a denial, or withdrawn application.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.

HMDA reporting and loan purpose

11/17/2024

If we have a consumer HELOC denial with the stated purpose of "purchase land to build a gas station," is it HMDA reportable?

HELOC historical table and SOFR

11/17/2024

Reg Z section 1026.40 requires us to disclose a historical table to reflect the most recent 15 years of index values. However, SOFR has only been available since 2018. Do we only need to disclose the years starting from 2018 even when the length of the plan is more than 15 years?

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