Most Popular Lending Content
Automatic Payment Rates-Rate Sheets
09/05/2011
In the past, we discounted our auto rates when a customer set up automatic payments. Going forward, we would like to set our rates sheets at a rate assuming automatic payments and then add 25bps to the rate if the customer does not wish to set up automatic payments. We would determine their wishes before disclosing the rate/APR and only disclose based on their given rate. Do you see any compliance issues with this providing that our rate sheets clearly indicate what is required to get the stated rate?
ROR Required on Construction (Primary Residence)?
09/05/2011
If we are paying off a construction loan for primary residence with permanent financing and the customers have moved into the new home, is ROR required?
Do Workout Loans Require Flood Determination?
09/05/2011
On workout loans when you are taking additional real estate collateral, (mortgage), is a Flood Determination required?
Reg O Apply to Loan Sold to Investor from Director
09/05/2011
If a mortgage loan is made to a Director of the bank and then sold to an investor, does Reg O apply?
Sufficient Info to Complete Application (GFE)
08/29/2011
In reviewing the FAQs from HUD concerning Early Disclosures (GFE), a loan originator must issue a GFE no later than 3 business days after the loan originator receives an application or information sufficient to complete an application. Application is defined as the submission of a borrower's financial information in anticipation of a credit decision relating to a federally related mortgage loan, which shall include the following: (1) borrower's name, (2) borrower's monthly income; (3) borrower's social security number to obtain a credit report; (4) property address; (5) estimate of value of the property; (6) loan amount and (7) any other information deemed necessary by the loan originator. When we receive an application online, it does not contain all the documents listed in our "application" (sales contract). Are we still required to send the GFE based on the information received that is considered "sufficient to complete the application".