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kmeadeParticipant
Exaggerator, Kathy Meade, Citizens Guaranty Bank, Group 3
kmeadeParticipantWe use Laser Pro (we do not use Mortgage Builder)and when we prepare the Closing Disclosure with the separate Seller’s Closing Disclosure it does list the Seller’s name and address on both documents. Contact me and I can forward copies of samples I have produced. kmeade@mycgb.com
kmeadeParticipant1026.36(i) Prohibition on financing credit insurance. (1) A creditor may not finance, directly or indirectly, any premiums or fees for credit insurance in connection with a consumer credit transaction secured by a dwelling (including a home equity line of credit secured by the consumer’s principal dwelling). This prohibition does not apply to credit insurance for which premiums or fees are calculated and paid in full on a monthly basis.
Hope this helps!
kmeadeParticipantI understood that VSI on mobile homes that are the primary residence was considered credit insurance and could not be financed. Is that correct?
kmeadeParticipantper 1026.19(4)(b)
kmeadeParticipantDortmund, Kathy Meade, Citizens Guaranty Bank, Group 3
kmeadeParticipantI have additional questions based on the original question. I you are using a modification can you raise the rate and add fees to the loan amount? If yes, do you have to have a rescission if it is their primary residence? If yes to that wouldn’t you need a TIL if you need a rescission? Also would or can the modification continue to cause the loan to be a balloon. If yes, how can you structure the balloon? We have considered this as well, so just looking for guidance.
kmeadeParticipantThank you, that is what I thought. We are not HMDA reporting bank.
kmeadeParticipantDance with Fate, Kathy Meade, Citizens Guaranty Bank, Group 3.
kmeadeParticipantI have looked at all the information above, but I still don’t see information concerning two dwellings as collateral on one loan, do both addresses have to be listed on the form. I can’t see where it even says the address has to be on the form, but we were cited in a prior exam because the lender had not filled in the property address on the form (our loan software does not fill in the address). So if we have two properties, do both have to be listed on the form or just one address?
kmeadeParticipantIf you choose to send a monthly statement instead of a coupon book, can you charge a fee at origination, example monthly statement fee (as a pre-paid fee)?
kmeadeParticipantWhen does the Yield Spread have to be disclosed?
kmeadeParticipantAre you allowed to use a modification or change in term agreement on a consumer real estate loan that is tied to an index (ARM loan – five year treasury) to lower the rate in the middle of a rate change cycle? It would require lowering the rate, margin and floor. What is your opinion on using this document for this purpose and what restrictions would apply?
kmeadeParticipantAre there any requirements on the appraiser emailing the appraisal to the lender? I heard that some banks have been sited because the appraiser emails the appraisal un-securely. Has anyone heard anything about this?
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