TOPIC: Home Equity

High Priced/High Cost Mortgage

Manager at a credit_union ($141MUSA)
Good afternoon:

I am hoping that someone might be able to share any tools or worksheets they use to determine if a mortgage (or fixed home equity loan) meets the high priced/high cost mortgage requirements as required by Reg Z.  Currently we outsource our 1st mortgage originations and they calculate this on those loans.  But we need to be calculating for our equities, which are processed in house.   

Also, if you have an excerpt from your lending policy that may address this, that would be especially helpful as well.

Thanks!

    Cash out Refinance of 1st lien mortgage (Homestead) and 2nd lien Home equity in California

    VP at a bank ($897MUSA)
    If a borrower wants to get a cash out refinance combining the original 1st lien mortgage and 2nd lien HE loan, is that possible? Also would it just be a considered a Cash Out Refi without having the HE requirements?  As stated in the subject this is in California and we have branches there.

     I am new to dealing with CA laws and have had trouble locating what I need to make a determination. So helpful answers and links to find the answers I need will be greatly appreciated. So far it appears structuring the loan as a Cash out refi will be fine. The cash out will be for business investment purposes and the HE funds were used for that as well. As far as TRID goes I will have to see what the majority of funds are going towards which is probably the refi of the mortgage but I haven't looked at the numbers of it all yet.