Policy Note: All Closing Disclosures (wholesale and correspondent) must be generated by Crescent Mortgage Company)

Transcription

1 TRID Closing Process with Crescent TRID/KBYO Closing process This process is only for loans subject to TRID/ KBYO. Loans not subject to rule (application date prior to 10/3/15) will continue to close under the same pre-trid process. Policy Note: All Closing Disclosures (wholesale and correspondent) must be generated by Crescent Mortgage Company) Contents TRID/KBYO Closing process... 1 Submit Closing Request Consultation to Confirm Fees:... 2 Navigation in Motion to Closing Request:... 2 Minimum Requirements to Submit Closing Request:... 2 Choosing your Estimated Close Date:... 3 Earliest Close Date that can be requested:... 3 Latest Close Date that can be requested:... 3 Complete the Main Contact field for the Closing Consultation:... 3 Review Closing Agent information... 3 Add Additional Comments... 4 Submit Closing Request... 4 Closing/Settlement Agent Request for fees and other information:... 4 Current Process:... 4 Process Effective Monday, Closing Disclosure Consultation... 5 Closing Disclosure Delivery... 5 Loan Estimate and Closing Disclosure Issuance and Responsible Party... 6 Timing... 6 Disclosure Event... 6 Responsible Party... 6 Changes to Closing Date or Fees... 6 Complete Closed Loan Package delivered... 7 Changes to Items at Consummation... 7 Example Closing Disclosure Timeline... 7 Page 1 of 7

2 Submit Closing Request Consultation to Confirm Fees: The TRID/KBYO closing process will have 3 components that need to be completed before the Closing Disclosure can be sent to the consumer: 1. Loan terms must be approved and not likely to change (rate, loan amount, program, loan term, mortgage insurance, etc.) 2. Closing/Settlement Agent and Seller information received and confirmed (Closing agent fee names and amounts, tax and recording fees, real estate agent info, tax pro-rations, license numbers for Closing agent or real estate brokers, etc.) 3. Fees must be reviewed and confirmed by your institution and a CMC Disclosure Analyst (origination, processing, invoices, POC items, etc.) Once your loan meets the minimum requirements below and you have a firm closing date, a request for Closing Disclosure Consultation can be made. The loan does NOT have to be Approved for Docs to make this request! (See requirements below). The loan officer, processor or other user within your institution can login and complete the Closing Request screen to start the closing process. Navigation in Motion to Closing Request: Alternative Navigation to Closing Request in Motion: Using Screen Search simply type: closing and select Closing Request Minimum Requirements to Submit Closing Request: Missing requirement will display in the validation on Closing Request Screen. Purchase Refinance Initial UW approval x x Purchase and Refi sections still apply USDA 1X Close Streamline specific CP specific Refi specific Interest rate locked x x NA Sales Contract x Appraisal Cleared x x NA Payoff x Initial RD approval x Insured Closing letter x x Validation items missing to submit closing request: All items validated to submit closing request: Page 2 of 7

3 Choosing your Estimated Close Date: The window for actual closing date that the Closing Request can be submitted for will be regulated based on whether or not E-Consent has been successfully executed by ALL parties on the transaction (all borrowers and all rescindable parties, i.e. title only borrowers, non-borrowing spouses in community property states, etc.). Earliest Close Date that can be requested: Consent for E-Delivery No Consent for E-Delivery Wholesale 5 days from current date 9 days from current date Correspondent 5 days from current date 9 days from current date Latest Close Date that can be requested: Consent for E- Delivery No Consent for E-Delivery Wholesale 10 days from current date 14 days from current date Correspondent 10 days from current date 14 days from current date Complete the Main Contact field for the Closing Consultation: Review Closing Agent information If incorrect, please contact underwriting or submit a revised ICL/CPL with the Closing Agent s information complete Closing contact and if missing. Page 3 of 7

4 Add Additional Comments If needed (i.e. Mail away to sellers needed by, POA being used, etc.) Submit Closing Request if no validation halts are received, you will see a pop-up message Closing Request Successfully submitted AND a date will populate in the Closing Request Submitted field. Closing/Settlement Agent Request for fees and other information: Once Crescent receives and approves the Insured Closing Letter (ICL) or Closing protection letter (CPL) with a valid address for the CMC Approved Closing/Settlement Agent: Current Process: A system generated will be sent to the Closing/ Settlement Agent with a sample Closing Disclosure Attached. The will contain the following information: Process Effective Monday, A System generated will be sent to the Closing/Settlement Agent with directions, a password and a link to a Closing Portal in Settlement Express. The agent will use this link, directions and password to Page 4 of 7

5 access the loan fees that pertain to the agent, tax pro-ration fields, licenses, commissions, etc. They can make proposed changes to fees, dates, paid to and paid by information for CMC to review / approve. Once completed, the information will come back to our Disclosure Analysts to enter into the loan and reconcile with the information and fees confirmed with the TPO. Settlement express closing agent fee collaboration tool effective Closing Disclosure Consultation Once we receive your closing request, a Crescent Mortgage Disclosure analyst will contact you by telephone. It is our belief that by contacting you by phone, we can quickly and accurately go over all of your fees, dates, invoices, paid to, and paid by information to ensure it is : Accurate, Up to Date, and Compliant. This should reduce the amount of s back and forth, set expectations of timing and delivery of the Closing Disclosure (CD), and answer any questions you may have regarding the Closing Disclosure and consummation. Once the closing disclosure consultation is complete, together we will formulate the date and delivery method for the borrower to receive the Closing Disclosure 3 days prior to settlement. Closing Disclosure Delivery The Closing Disclosure (CD) must be RECEIVED by the borrower three days prior to closing. The chart below shows when the CD would have to be mailed (if mailed) and received by the borrower to close on schedule. The Closing Disclosure (CD) will be generated and delivered to the borrower(s) when the following are completed: 1. Closing/Settlement Agent requirements are received and complete. 2. Origination/TPO fees are reviewed and complete. 3. No LE CIC s are required/pending. 4. Timing Requirements are met. Page 5 of 7

6 Loan Estimate and Closing Disclosure Issuance and Responsible Party Timing Disclosure Event Responsible Party Fees finalized and closing request submitted Closing Disclosure Wholesale Transaction: CMC Disclosure Analyst submits preliminary CD to closing agent and collaborates to prepare. Once finalized, CMC Disclosure Analyst sends to consumer via E-Delivery with prior to consent or US Mail. Correspondent Transaction: CMC Disclosure Analyst submits preliminary CD to closing agent and collaborates to prepare. Correspondent can deliver a CD with signature line to show evidence of receipt. Correspondent can use CD prepared in Motion to e-deliver to borrower if using CMC approved E-Sign vendor. Correspondent can E- Deliver, or ask CMC Disclosure Analyst to E-Deliver the CD via Motion platform with prior consent. Closing Revised CD If any revisions to CD occur that do not trigger new waiting period, they will be delivered by CMC to settlement agent as soon as known and finalized, but no later than initial closing date disclosed to borrower. Changes to Closing Date or Fees Any changes to the closing date subsequent to the closing disclosure consultation must be reviewed by CMC Disclosure Analyst. Any changes to fees due to changing of closing date (example, a lock extension fee is assessed) must be reviewed and disclosed by CMC Disclosure Analyst NO LATER THAN THE INITIAL ESTIMATED CLOSING DATE disclosed on the Closing Disclosure delivered to the borrower. Crescent Mortgage will not make cures on wholesale transactions whose closing date changes by more than 7 days if we are not notified of the change by the initial closing date disclosed on the closing disclosure to the borrower. Page 6 of 7

7 Complete Closed Loan Package delivered When the status on the loan is updated to Approved for Docs by Underwriting and the Closing Disclosure has been delivered to all borrowers, the Closing Package can be generated and distributed by you or someone in your institution as it has been pre-trid. Using the Get my Docs screens, the user will be able to generate documents when: 1. Loan is Approved for Docs 2. Closing Disclosure indicates as Received User will need to review the Earliest/Latest available close dates based on document effective dates, expiration dates, CD Received date (mailbox rule OR actual retrieval via E-sign or Ink Sign) and choose the closing date. After closing date is selected, user can generate the closing package and distribute to the closing agent. Changes to Items at Consummation Any changes to the Closing Disclosure at consummation will need to be communicated by settlement agent via Settlement Express link (identical to current HUD approval process) Example Closing Disclosure Timeline TITLE / INSURED CLOSING LETTER APPROVED CLOSING REQUEST RECEIVED CLOSING CONSULTATION OCCURS FEES RECONCILED WITH SETTLEMENT AGENT CLOSING DISCLOSURE DELIVERED IF BY MAIL CLOSING DISCLOSURE DELIVERED IF BY E DELIVERY CONFIRMED BORROWER RECEIPT OF CLOSING DISCLOSURE SETTLEMENT DATE NOVEMBER SPECIFIC BUSINESS DAY CALENDAR M T W T F S Page 7 of 7