I recently attended a real-estate lending class where Jack presented and had a couple of follow-up questions upon reviewing my notes:
1. I believe he made the statement that the 4% late fees and the 15 day grace period timing requirement in 1026.34(a)(8)(i) is retroactive for all our HOEPA loans? Is that correct? If so, how far back do we go to make that retroactive, since the inception of HOEPA loans?
2. Is it a requirement to track loans that have been redisclosed? For example, we have a changed circumstance and redisclose the earlies, should we be tracking that for any reason? What about redisclosure of the HUD? I couldn’t find this in the reg. or commentary but wanted to clarify.