Most Popular Lending Content
Guidelines for Writing "Change of Terms"
08/01/2011
We write a bunch of change of terms every month. The reason for the COTs range from interest only payments, lower interest rates, update delinquencies and change name on the title. I’m looking for your opinion on when we need new Loan Agreements/security agreements. I’m looking to add many of the disclosures from our loan agreement to the back of the COT form, so the member doesn’t have to sign new loan agreements. I am running across confusing language in the regulations. I’ve seen an article that says skip payments and do not require new disclosures because that doesn’t constitute a refinance. I’ve also heard that refinance may involve the rescheduling of payments. My ultimate objective is to make it easier for the loan officers to create COTs. It is very time consuming at the moment.
Credit Score Disclosure Notice Requirement
08/01/2011
We do not price consumer loans based on risk, and thus, we are not required to provide the risk based pricing notice. Are we required to continue to provide the credit score disclosure notice on loans secured by 1-4 family residential real property as stipulated under Section 1681g?
Refinancing Loan w/ Second Lien Home Equity
08/01/2011
We have a customer who would like to refinance his homestead which is a first lien purchase money. The customer has a second lien home equity against it. Can I refinance the first lien as a conventional mortgage and refinance the home equity and cash out the additional equity in a second lien? Do I combine and fund one loan as home equity? I have always heard "once a home equity, always a home equity". Please clarify for me.
Providing Proof of Income on Non-Mortgage Products
08/01/2011
Are there any regulatory requirements for providing proof of income on non-mortgage products?
"Due on Demand" Clause- Executive Officer Loans
08/01/2011
Is it still a requirement that all executive officer loans contain a "due on demand" clause as well as other normal terms?