If we are doing a refi on a farm with a homestead located on it and it is FSA guaranteed we don't have to do TRID correct since this would be considered a commercial loan correct.
It may depend on the exact details behind the loan, but probably not. As Comment 3(a)-8 of Regulation Z states, “The [agricultural] exemption also applies to a transaction involving real property that includes a dwelling (for example, the purchase of a farm with a homestead) if the transaction is primarily for agricultural purposes.” Remember, you look at the purpose of the loan, not necessarily the purpose of the collateral.
What happens if an HSA account becomes overdrawn due to a forced debit card transaction?
That likely would be a “prohibited transaction” (just like pulling money out to spend on something non-healthcare related), which could cause the account to lose its HSA status. While it isn’t the bank’s responsibility to make sure the account isn’t overdrawn, it is best practice to prevent overdrafts from happening in an HSA account.
If there are joint borrowers, does a bank comply with Regulation B if they deliver the appraisal to one of the borrowers versus both 3 days prior to closing?
It is a best practice to send to both of the borrowers, but it is not necessarily required under Reg. B.
As long as one (the primary) applicant is sent the appraisal three days prior to closing you will meet the requirements under the Reg. The official interpretations to 12 CFR §1002.14(a) provide guidance:
"14(a) Providing appraisals and other valuations.
1. Multiple applicants. If there is more than one applicant, the written disclosure about written appraisals, and the copies of appraisals and other written valuations, need only be given to one applicant. However, these materials must be given to the primary applicant where one is readily apparent. Similarly, if there is more than one applicant for credit in the transaction, one applicant may provide a waiver under §1002.14(a)(1), but it must be the primary applicant where one is readily apparent."
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