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Question 2:
If we have a loan with a single annual payment of principal and interest, do we disclose this full balloon payment in the monthly P&I payment section of Loan Terms on page 1 of the LE & CD? Example: $100,000 loan at 5% interest = 1 payment of $105,000 due at maturity. Our LOS is telling me the CFPB has advised them this is how it should be disclosed. I have not heard this anywhere else.What is the term of this loan? Is this a one time balloon payment or does the borrower make one payment of $105,000/year for X years?
—-It is a one-time balloon payment.
Robin, just when I think I understand I find other opinions that lead me to feel otherwise. Below is a link to a BOL thread discussing changed circumstances and tolerances after the initial Closing Disclosure has been issued.
https://www.bankersonline.com/forum/ubbthreads.php?ubb=showflat&Number=2010582&gonew=1#UNREAD
Robin, if we do have a changed circumstance affecting tolerances and we re-disclose on the Closing Disclosure prior to consummation, do we not have to provide any rebates for tolerance cures? Further, how would the revised charges be displayed on the Cash to Close comparison chart? Would we show the revised charges under both the Loan Estimate & Closing Disclosure columns or only under the Closing Disclosure column?
Jack, the deposit account where we remit funds to the vendor is held in the Bank’s name and therefore why the payee is Bank for benefit of Vendor.
Thank you! The CMG sessions on TRID over the past year have been a great help.
That’s what we were looking for. We do not want any issues in this area. Thank you for the heads up!
One more I forgot…
3. We have an agreement with our Flood provider and we are to collect the flood fee, place it in a deposit account under the Bank’s name to be debited by the flood company. How will this be disclosed on the new Loan Estimate? We currently state it payable to “Bank Name FBO Vendor Name” as the ultimate payee is the vendor.
Thanks!
A few questions from last week’s meeting…
1. It costs $12 to have a mortgage document released in Tennessee. We collect this up-front from the customer and retain it in a general ledger account until the loan is paid off. Would this future release fee still be considered “Paid to” the Government as a recording fee?
2. We have an affiliate title insurance company. Just to ensure I understand the service provider list procedures…If we allow to shop and include the affiliate on the list of providers, and the customer uses the affiliate, we have a 10% tolerance. If we allow to shop but fail to provide a list, and the customer uses the affiliate, we have a 0% tolerance. Am I correct?And, if we do not allow to shop, and the customer uses the affiliate, what is the tolerance?
