TILA Reg Z part 2 Flashcards

1
Q

For Reg Z, what must an ARM be secured by to be considered an ARM? and how long should term be?

A

principal dwelling and term more than 1 year

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2
Q

when must the CHARM booklet and program disclosure be provided for ARM loans?

A

at time of application

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3
Q

If a creditor makes fewer than X loans under TRID in a year they are exempt?

A

5 or fewer mortgage loans

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4
Q

what constitutes application under TRID?

A
  • loan amount
  • property address
  • name
  • SSN
  • income
  • property value
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5
Q

what is general business days?

A

day a bank is open and carries substantial amount of there business

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6
Q

what is the mailing rule?

A

assume post office takes 3 specific days to deliver

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7
Q

How many days does bank have between LE before they can close?

A

delivered or mailed 7 specific days before consummation

This only applies to first/original LE.

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8
Q

Can a bank waive the 7 day rule before closing?

A

Yes if customer has bona fide personal financial/health emergency

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9
Q

what is a changed circumstance?

A

reset baseline

  • applicant requests change (variable to fixed)
  • floating interest and now locked (revised LE required)
  • if intent to proceed not received within 10 a revised LE may be sent
  • information that changes assumptions (appraisal value, credit score)
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10
Q

True or False

For HPML, banks must escrow for taxes and insurance for the entire life of loan.

A

False

For first lien loans, borrower may be given the opportunity to opt out of the escrow after 5 years.

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11
Q

what are the requirement to be a HPML?

A
  • -closed
  • -secured by principal dwelling
  • -lien position is irrelevant
  • -includes home equity, purchase, refinance, etc.
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12
Q

what loans are covered under HOEPA?

A
  • -consumer purpose
  • -secured by principal dwelling
  • -includes purchase, home equity, refinance and HELOC
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13
Q

what makes a loan a HOEPA loan?

A

one of the following

  • -APR is 6.5% over APOR for first lien and 8.5%
  • -loans total points and fees exceed threshold
  • -prepayment penalty can be charged more than 36 months out of more than 2%
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14
Q

what are some requirements for HOEPA loans?

A
  • -additional disclosures
  • -homeowner counseling required
  • -limitations on prepayment penalties and fees
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15
Q

what is a higher risk mortgage?

A

an HPML that is NOT a qualified mortgage

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