RSK.IQ Archives • Page 54 of 122 • RSK Compliance Solutions LLC

RSK.IQ Question of the Week 10/23/2017

Posted on October 23, 2017October 23, 2017 by RSK.IQ.Staff

Regulation Z, Ability-to-Repay, and ARMs

Issue/Inquiry

The Bank would like to know if there are specific rules for calculating the consumer’s ability to repay when there is an adjustable rate mortgage. If the mortgage loan will include multiple interest rate adjustments over the term, at what rate does the Bank qualify the customer?

RSK.IQ Question of the Week 10/16/17

Posted on October 16, 2017October 13, 2017 by RSK.IQ.Staff

Refinancing and Paying Off a Loan from a Private Party

Issue/Inquiry

If the Bank is making a loan to pay off a loan made by a private party to the same borrower and secured by the same dwelling, is this considered a refinance?

RSK.IQ Question of the Week 10/9/2017

Posted on October 9, 2017October 6, 2017 by RSK.IQ.Staff

TILA Disclosures for Assumptions

Issue/Inquiry

The co-borrower on a residential mortgage loan has requested to be released from the obligation. The Bank has agreed to do so, on the condition that another co-signer is added. The terms of the loan are not changing and the Bank is not refinancing it. The transaction will be documented with a restated note or assumption agreement. Is the Bank obligated to make loan disclosures to the co-signer?