[jsevers]

Hoping for some assistance.
We have a Bridge loan product that is 12 months interest only with a balloon payment at the end of the term. Upon review of the consummated file (closed April 20) it was discovered that the balloon feature was omitted from the Loan Estimate and Closing Disclosure under the Loan Terms section on page 1. The closing documents do reflect a balloon payment feature and amount which was executed by the borrower. My initial thought is to provide a post consummation CD. I am hoping you could provide guidance on whether or not there are any additional consequences to this omission.

If you could also provide any sources or commentary regarding this issue. I am having difficulty finding a resource.

[jsevers]

Loan application received with a requested loan amount of $130,000. Initial disclosures sent within 3 business days indicating a 1 point fee and a 2.625 origination fee. Bank received notification borrower requested increase in loan amount to 180,000. Revised LE not completed and sent. Loan was re-approved at higher loan amount three weeks prior to closing. Once closing was scheduled, the CD was produced indicating the increase in origination/point fees. Without a revised LE to reset the baseline, would the increase in these 0% fees be considered a tolerance cure and reimbursable to the borrower at post consummation?

Application date: 8/27/19
LE sent 8/29/19
Borrower requests increase: 10/9/19
Re-approval 10/9/19
CD produced indicating increase 10/29/19 – hand delivery
Loan closed 11/1/19

Please provide guidance if a cure and reimbursement is required.
Thank you,
Jenny

[jsevers]

Can you tell me how I would quote Exhibit B Title endorsements on a loan estimate under our Affiliate Service providers? they charge 10% of the owners premium, which will always be different depending on sales prices. They do have minimums of $75.00. This charge is on top of the $150 we already show for Title Endorsements. Is there a best practice for disclosing this at LE? I know this is a service that can be shopped and if they do not shop it is subject to the 10% tolerance. Any advice or what you have seen being done regarding this? This pertains to Mineral rights… WE are in PA if that helps…
thank you
Jenny Severs

[jsevers]

I am too in need of the following clarification:
When issuing an adverse action notice to a borrower for reasons unrelated to credit (ie: Loan to value, length of employment, residence) are we required to list the key factors and the credit score on the notice? We have historically always provided this information in all instances of AAN. If someone could clarify.
thank you
Jenny

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