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The available filters are age, income, gender, marital status, homeowner/renter, home value, households with children, length of residence, and year home built.
Also, to clarify the question, if the final inspection changes the value, wouldn’t we need to wait if a new value is given?
Also, if the business is a startup businses with no gross annual revenue history yet, would we use the figure of 0 or use projections? Thank you.
The mortgage department is a division of our bank, so yes, I would say it is within the bank. The mortgage department is not a separate legal entity.
To clarify, assume that the E-sign Act requirements are met when the customer picks up/receives/consents at the time of the early disclosures/Loan Estimate. Also assume the CD has already been provided 3 days or more prior to loan closing/consummation/origination, and that there are no changes needed for the final CD. The documents I am asking about are the note, final copy of CD, and right of rescission provided at closing. When the customer is using electronic delivery and signing, we will send the docs electronically. How much time can we allow for the borrower to pick up/receive/sign those documents? The desire by management is to allow 5 days without refreshing the documents, without updating/changing the CD. In other words, if the note, final CD copy, and Right of rescission are sent electronically on a Monday, if the borrower electronically signs and sends back to us that day, we have actually closed the loan the date of the note and final CD. However, if the borrower does not sign on Monday, and the borrower signs on Tuesday-Friday, are we ok to use those same docs provided Monday with the Monday note and CD date, without refreshing/uploading new docs, and use Monday as the origination date for interest just as the note states when entering the loan on our core processor?
Our Right to cancel states that the 3 day period starts the later of the day the account is opened, the dat the TIL is received, or the date the right to cancel is received, so that seems to adjust forward the rescission date for us, and we would give them 3 days to rescind after signing, if not signed same day as note date.
I can understand giving the customer a day or two, because the borrower may not be available that same business day the docs are sent to them. That seems reasonable, but the desire is to allow 5 days, and I want to make sure there would be no issue with that.
Thank you for those resources, this is helping, but I am a little concerned that if the customer has already contacted the merchant and the merchant did not yet resolve the issue to the customer’s satisfaction, at what point does that merchant dispute become a dispute subject to Reg E? If the customer is disputing the quality of the goods or services received, that seems to fall under the merchant disputes not subject to Reg E. But if the customer has contacted the merchant, and either did not receive a credit or is still unsatisfied, would that information on our Reg E Dispute form cause the merchant dispute to be subject to Reg E?
Similarly, if the merchandise arrived damaged, or the customer just decided to make a return, that seems to be a merchant dispute not subject to Reg E. However if the customer sent it back for a return but never received credit, would that information included on our Reg E Dispute form signed by the customer cause the merchant dispute to be subject to Reg E?
We plan to offer 90 day payment deferrals or up to 180 days interest only, but do not plan to extend out the maturity date. Would this be a MIRE event?
Sorry! the form is required by our core processor so that they can help us with the investigation of disputes.
I would agree with that, and since we don’t have an opinion as to whether a portion of the home can be saved, I plan to include the application on the HMDA LAR. Thanks!
Would it comply with FDPA to take the approach of going straight to the discretionary criteria review for all private policies lacking the compliance aid statement?
When I think about the fee from a banking standpoint it sounds modest, but from a consumer standpoint, I would consider it high. We have 2 different quotes from 3rd parties, one high, one low, with the primary difference being the low cost estimate only covers a mandatory acceptance review and no discretionary review should the policy not comply, whereas the more expensive quote covers the discretionary acceptance guidelines when the mandatory guidelines are not met. The fee though, would cover an initial review, with a little left over, as policies renew each year and can change. So is it reasonable, I believe it would be.
That brings me to the question, if we, or a 3rd party we contract with, conduct a review using the mandatory acceptance guidelines and the policy does not comply, the regulation says a bank may then accept the policy under the discretionary guidelines. Is a bank required to complete a discretionary guideline review to try to be able to accept the policy?
The flat fee would be called something like “flood processing fee” or “flood insurance processing fee” or something similar to that. The fee would cover the bank’s cost of a review of the flood insurance policy if a private policy lacking the compliance aid statement exactly, and general administrative costs for monitoring loans located in a SFHA for current insurance, etc… We have a 3rd party that tracks our insurance for us, and sends out the force place insurance letters for us. However there is still monitoring the bank has to do of the 3rd party’s reports, such as provide the amount of insurance required each year, charge the customer for force placed insurance in some instances. The fee would only be on loans located in a SFHA.
To clarify the customer need only respond to the offer, not the bank originate the loan within 60 days, is that correct?
We have a situation where the credit report was pulled 12/7/16 and we use the credit report MLA indicator. However the application is dated 2/3/17 and the loan originated 2/7/17, more than 60 days after the MLA status check on 12/7/16. The lender used a credit report pulled for a different request by the same borrower. Do I ned to compare 12/7/16 to the application date (is within 60 days) or the loan origination date, (is not within 60 days of MLA determination)?
