Loan Products and Services
Four statutes cover most loan questions
TILA/Reg Z (disclosure and APR), RESPA/Reg X (settlement, escrow, kickbacks), ECOA/Reg B (access and adverse action), and HMDA/Reg C (data) sit alongside flood insurance, SCRA, and the ability-to-repay and qualified mortgage rules.
Mechanics a candidate must know:
- Finance charge and APR. The APR reflects the finance charge as a rate over the term, not the note rate. Points, credit insurance, and certain closing costs generally enter the finance charge.
- TRID. Loan Estimate within three business days of application; Closing Disclosure at least three business days before consummation; three tolerance buckets (zero, 10 percent cumulative, and unlimited).
- Rescission. Three business days, principal dwelling only, for refinances and home equity lines; never for a purchase-money loan or a business-purpose loan.
- Adverse action. Notice within 30 days, with specific reasons or disclosure of the right to request them.
- Escrow and insurance. HPML escrow requirements, mandatory flood purchase and force-placement timing, and PMI termination at 78 percent of original value automatically or 80 percent on borrower request.
Traps
- Quoting the note rate when the question asks for the APR.
- Applying a 10 percent tolerance to lender fees, transfer taxes, or shoppable services where the consumer chose an affiliate; those are zero tolerance.
- Counting only Monday through Friday as business days for the Closing Disclosure; Saturdays count.
Worked example
Consummation is Monday. Count back three business days, excluding Sundays and federal holidays but counting Saturday: Friday (1), Thursday (2), Wednesday (3). The Closing Disclosure must be delivered by Wednesday.