Presentation by Janet M. Bonnefin Aldrich & Bonnefin, PLC
|
|
- Francine Carson
- 5 years ago
- Views:
Transcription
1 Washington Bankers Association 2015 Northwest Compliance Conference TRID We re Down to the Wire! Presentation by Janet M. Bonnefin Aldrich & Bonnefin, PLC Agenda Creditor s duty to give Loan Estimate Restrictions on charging fees at time of application Good faith determination of borrower s costs (tolerances) Avoiding tolerance violations Creditor s duty to provide Closing Disclosure Issuing corrected Closing Disclosure Post-consummation changes Correcting tolerance violations 1
2 Disclaimer This presentation is intended solely for educational purposes to provide you general information about laws and regulations and not to provide legal advice. There is no attorney-client relationship intended or formed between you and the presenter. Consult your institution s legal counsel for advice about how this information impacts your institution. Important Definitions 2
3 Business Day Two Definitions General definition Day on which creditor is open for carrying on substantially all of its business functions May include Saturdays and Sundays if you re open, depending on the extent of the services you offer on weekends Precise definition All calendar days excluding Sundays and 10 defined legal holidays (same as rescission definition) Consummation Consummation is when the consumer becomes contractually obligated on a credit transaction State law governs Generally it is when the consumer signs the debt instrument (promissory note, loan agreement, etc.) 3
4 Duty to Give Loan Estimate Creditor s Responsibility Creditor is responsible for providing Loan Estimate Within 3 business days of receipt of application General business day definition A day your institution is open to the public for carrying on substantially all of its business functions 4
5 Mortgage Brokers Mortgage broker may give LE but creditor is still responsible for it Creditor may not issue a revised LE to correct broker s errors But may issue a revised LE if an event occurs which permits creditor to issue one (more on this later) Application Defined Application consists of 6 items of information ALIENS A = Address of property L = Loan amount I = Income of consumer E = Estimated value of property N = Name of consumer S = Social security number 5
6 May Request Additional Info & Documentation Creditor is allowed to request more information than just ALIENS E.g., general application form, FNMA 1003, etc. Creditor may also request documentation to verify consumer s information Pay stubs Tax returns Signed verification forms But... creditor must provide LE once it has ALIENS, even if it hasn t received the additional information or documentation it requested Preapprovals Are Not Dead When consumer is shopping for a new home, usually he has not identified a property or have an estimated value of the property (the purchase price) When consumer applies for a preapproval, you don t have the A or E in ALIENS Thus the request for preapproval is not considered an application under TRID, so you don t have to provide an LE yet When you get the A and E, give Loan Estimate within 3 business days 6
7 Manner of Delivery In person By regular mail Overnight delivery (USPS, UPS, FedEx, etc.) Creditor may deliver Loan Estimate electronically, but must comply with E- Sign Act first E-Sign disclosure Consumer s consent given electronically 7-Business-Day Waiting Period There must be 7 business days between when Loan Estimate is mailed or delivered and consummation 7-business-day waiting period starts when LE is mailed or delivered Consummation can occur on 7th business day Precise business day definition applies All calendar days except Sundays and 10 legal holidays 7
8 When Consumer is Deemed to Receive LE Hand delivered: same day By mail: 3-business-day mailbox rule You may instead rely on evidence (documentation) of earlier receipt By Must comply with E-SIGN Act 3-business-day mailbox rule You may instead rely on evidence (documentation) of earlier receipt Why Do We Care When Consumer Receives LE Two Reasons Reason #1: Creditor/broker may not impose a fee (except for credit report fee) until consumer Receives LE; and Indicates an intent to proceed with the loan Reason #2: If creditor issues a revised LE, consumer must receive it at least 4 business days prior to consummation We ll discuss issuing revised Loan Estimates later 8
9 Waiver of Waiting Period Permitted Consumer may waive 7-business-day waiting period Needs bona fide personal financial emergency Creditor must decide if emergency qualifies Still must give Loan Estimate first Waiver must be in writing Signed and dated by all consumers Must expressly waive waiting period No preprinted forms Example #1 Loan Estimate Timing ABC Bank receives a consumer s application for a home improvement loan on Monday, October 5, ABC Bank is closed on Saturdays and Sundays. 1. ABC Bank must deliver or place the Loan Estimate in the mail by. 2. If ABC Bank hand delivers or places the Loan Estimate in the mail on October 7, 2015, then loan consummation may occur on or after. SUNDAY MONDAY TUESDAY WEDNESDAY THURSDAY FRIDAY SATURDAY Application Received
10 Restrictions on Charging Fees No one can collect any fees until Loan Estimate is delivered AND Consumer expresses intent to proceed Only exception Bona fide and reasonable credit report fee Good Faith Determination (aka Tolerances) 10
11 Good Faith Determination of Charges Closing costs deemed to be made in good faith if charge consumer pays at closing doesn t exceed the amount disclosed on the Loan Estimate So consumer must be charged the same as what was stated on Loan Estimate, unless the increase is within the applicable tolerance Three Categories of Tolerances Zero tolerance items Origination charges Fees charge by service providers the creditor controls 10% aggregate tolerance items Fees charge by service providers consumer selects from provider list or doesn t select at all Items not subject to limit at all Unlimited variations permitted for certain fees 11
12 Zero Tolerance These fees are always subject to a zero tolerance Fees paid to creditor or mortgage broker Fees paid to affiliate of creditor or broker Transfer taxes Fees paid to unaffiliated third party if the creditor did not permit the consumer to shop for the third-party service provider Zero Tolerance Examples Examples of services consumers typically cannot shop for: Appraisals Credit reports Flood determinations Therefore these fees are subject to a zero tolerance 12
13 10% Aggregate Tolerance Recording fees Third-party fees where consumer: Can shop for service provider and Chose one from creditor s provider list or made no selection at all This tolerance doesn t apply to fees paid to creditor or broker, or their affiliates These would be zero tolerance fees 10% Aggregate Tolerance (cont d) Examples of service providers consumers usually can shop for: Settlement agents Title companies Therefore, these fees are eligible for 10% tolerance 13
14 10% Aggregate Tolerance Example Total fees disclosed on LE subject to 10% aggregate tolerance = $750 So the tolerance is $75 If one or more fees increase by a total of $70, creditor made a good faith determination But if one or more fees increase by a total of $80, there would be a tolerance violation Unless creditor takes corrective measure That is, issue a revised Loan Estimate if permitted Or refund the difference Certain Variations Permitted Without Limit Prepaid interest Property insurance premiums Amounts placed in escrow account Charges paid to third-party service providers selected by consumer not on creditor s list E.g., consumer purchases title insurance from a company not on creditor s written provider list Charges paid for third-party services not required by the creditor These can be paid to creditor s affiliates Property survey fee Real estate agent s commission These aren t really subject to an unlimited tolerance The original estimate still must have been based on the best information reasonably available You can t just guess or wildly over inflate the figures 14
15 ABC Bank discloses a $400 escrow (settlement agent) fee on the Loan Estimate Assume the consumer is allowed to shop for the escrow agent and ends up choosing an escrow agent (not affiliated with ABC Lender) from ABC s Written Provider List Is the $400 escrow fee subject to a Zero tolerance (no deviation allowed)? 10% aggregate tolerance? An unlimited variation? Exercise #2 Same facts as above but the consumer instead chooses an escrow agent that is not listed on ABC s Written Provider List Is the $400 escrow fee subject to a Zero tolerance (no deviation allowed)? 10% aggregate tolerance? An unlimited variation? Exercise #3 15
16 Avoiding Tolerance Violations Issue Revised LE Tolerance violations can be avoided in certain circumstances by issuing a revised Loan Estimate Issuing revised Loan Estimate is optional in all cases except... Creditor must issue a revised LE when the creditor and consumer agree to lock the interest rate or the rate is relocked Timing for Revised LEs Creditor is to issue revised LE within 3 business days (general definition) of receiving info that allows the creditor to issue a revised LE Consumer must receive the revised LE at least 4 business days (precise definition) prior to consummation 16
17 When Creditor May Issue Revised LE Changed circumstances Consumer s eligibility is affected Consumer requests a change Interest rate is locked (or relocked) Loan estimate expires after 10 business days Delayed settlement date in connection with initial construction loan Interest Rate Lock If interest rate is locked (or relocked), creditor is required to issue a revised LE Timing within 3 business days following the date the interest rate is locked Revised Loan Estimate to include Revised interest rate Points disclosed Lender credits Any other interest rate dependent charges and terms 17
18 Loan Estimate Expires in 10 Business Days If consumer indicates intent to proceed more than 10 business days (general definition) after original Loan Estimate was issued, creditor is not bound by the original LE Creditor may Continue to use original Loan Estimate or Issue a completely new Loan Estimate or Issue a revised Loan Estimate No justification other than the passage of time is needed to issue a new or revised Loan Estimate Delayed Consummation Date on New Construction Loans Rule applies to new (initial) construction loans If creditor reasonably expects consummation to occur more than 60 days after providing Loan Estimate Then creditor may provide revised Loan Estimate at any time up to 60 days before consummation 18
19 Delayed Consummation Date on New Construction Loans (cont d) Creditor must include required statement on page 3 of the original Loan Estimate in Other Considerations section You may receive a revised Loan Estimate at any time prior to 60 days before consummation Scope of Special Construction Loan Rule Coverage limited to Loan for the purchase of a home that has yet to be built, or Loan to purchase a home currently under construction Does not apply to Home improvement or remodeling loans Loan if use and occupancy permit issued before Loan Estimate issued 19
20 Consider Whether You Should Use This Exception Note that construction lenders are not required to use this exception in order to issue a revised Loan Estimate because there is a downside to using this exception If creditor provides a Loan Estimate that would not otherwise be permitted by the other five exceptions, the creditor must wait at least 60 days after issuing the revised Loan Estimate before it can consummate the loan Creditors instead may choose to issue a revised Loan Estimate only if permitted by the other five exceptions in which case the creditor is not required to wait 60 days before consummating the loan Timing After Issuing Revised Loan Estimate Consumer must receive revised LE at least 4 business days prior to consummation Precise definition of business day applies If LE not delivered in person, consumer deemed to receive revised LE 3 business days after it is mailed So = 7 business days At least 7 business days must elapse between when Loan Estimate is mailed and when consummation can occur 20
21 Closing Disclosure Duty to Provide Closing Disclosure Creditor has the responsibility to provide Closing Disclosure Creditor may divide up responsibility with settlement agent Creditor must provide Closing Disclosure at least 3 business days before consummation Precise business day definition 21
22 Duty to Provide Closing Disclosure Consumer may waive the 3-day waiting period, according to the same rules as the Loan Estimate waiver You cannot issue a revised Loan Estimate once you issue the Closing Disclosure When Consumer is Deemed to Receive CD Same as Loan Estimate receipt rules Hand delivered: same day By mail: 3-business-day mailbox rule You may rely on evidence (documentation) of earlier receipt By Must first comply with E-SIGN Act 3-business-day mailbox rule You may rely on evidence (documentation) of earlier receipt 22
23 Example #4 ABC Bank receives a consumer s application for a home improvement loan on Monday, October 5, ABC Bank is closed on Saturdays and Sundays. The lender must deliver or place the Loan Estimate in the mail by Thursday, October 8, 2015, in which case consummation can occur on or after Saturday, October 17. SUNDAY MONDAY TUESDAY WEDNESDAY THURSDAY FRIDAY SATURDAY October Application Received Loan Estimate mailed or delivered in person Columbus Day Consummation can occur Consummation scheduled Example #4 (cont d) 1. If consummation is scheduled for Monday, October 19, 2015, and ABC Bank will be delivering the Closing Disclosure in person, ABC must hand deliver the Closing Disclosure by October. 2. If consummation is scheduled for Monday, October 19, 2015, and ABC Bank will be mailing the Closing Disclosure, ABC must place the Closing Disclosure in the mail by. 3. On Thursday, October 15, the consumer requests a change to the loan, going from an adjustable-rate mortgage to a fixed-rate loan, which increases several charges beyond the applicable tolerances. a. In order to avoid tolerance violations, ABC would have to issue a revised Loan Estimate by October. b. If ABC issues a revised Loan Estimate on that date, the earliest consummation may occur is October. c. In that case, ABC must issue the Closing Disclosure by October. 23
24 Basis for Closing Disclosure Based on actual terms No markups are allowed ( (f)(3)(i)) Exception: Charging the consumer for the average charge of the settlement service Creditor required to comply with the average charge rules in Section (f)(3)(ii) Creditor must exercise reasonable diligence to get best information reasonably available May rely on third parties May do so even if the creditor knows that more precise info will be available Don t label anything as an estimate Transactions Involving Sellers In the case of a purchase-money loan involving a seller, the settlement agent must provide the seller with the portions of the Closing Disclosure that relate to the seller s transaction Timing the settlement agent must provide the seller s portions of the Closing Disclosure no later than the day of consummation (and send a copy to the creditor) If there are changes to the amounts paid by the seller within 30 days following consummation, the settlement agent is required to deliver or place in the mail a corrected Closing Disclosure within 30 days of learning of the change (and send a copy to the creditor) 24
25 Corrected Closing Disclosures Issuing Corrected Closing Disclosures Creditor is required to issue a corrected Closing Disclosure if CD doesn t reflect Actual terms of the transaction or Actual costs associated with settlement Two categories Pre-consummation corrected CDs Post-consummation corrected CDs 25
26 Issuing Corrected Closing Disclosure Pre-Consummation Some changes trigger corrected CD and new 3-business-day waiting period 1. APR out of tolerance Regular transactions: 0.125% Irregular transactions: 0.250% Also other APR tolerances in Section Change to loan product 3. Creditor adds a prepayment penalty Other Changes to Closing Disclosure Pre-Consummation Other types of changes don t trigger new 3-day period For example, seller credit increases by $500 the day before loan signing But creditor must still provide corrected CD at or before consummation And creditor must make corrected CD available for consumer s inspection one business day (general definition) before consummation 26
27 Post-Consummation Changes If an event occurs within 30 days following consummation that changes the amount the consumer actually paid For example, recording fee Creditor is required to issue a corrected Closing Disclosure Provide corrected CD within 30 days of learning of event Non-numeric Clerical Errors A creditor does not violate the Closing Disclosure requirements if it corrects non-numeric clerical errors within 60 days after consummation by sending a corrected Closing Disclosure For example, typo in name of settlement service provider or mortgage broker 27
28 Correcting Tolerance Violations If actual costs paid by the consumer exceed Loan Estimate amounts (beyond tolerance), refund overcharge within 60 days Deliver corrected CD (reflecting refund) too Questions? Contact Information Janet M. Bonnefin Principal Aldrich & Bonnefin, PLC Von Karman Ave., Suite 300 Irvine, CA
The TILA-RESPA Integrated Disclosures Rule consolidates. Estimate (GFE) into the Loan Estimate and. the Closing Disclosure
Agenda This training consists of three parts explaining the general requirements of the law that consolidated multiple disclosures into two separate forms; the Loan Estimate and the Closing Disclosure:
More informationWhat is T.R.I.D TILA-RESPA Integrated Disclosure
T.R.I.D. What is T.R.I.D TILA-RESPA Integrated Disclosure The CFPB has issued a rule that is aimed to simplify and improve disclosure forms for mortgage transactions. The rule replaces the current forms
More informationTRID Quick Reference Guide
TRID General Rules and Definitions New Required Disclosures Loan Estimate (LE) replaces the GFE and Initial TIL Closing Disclosure (CD) replaces the Final TIL and HUD-1 Home Loan Toolkit replaces the HUD
More informationTRID. Acceptable Broker Submissions Booklet WHSL EQUAL HOUSING LENDER MEMBER FDIC NMLS #478471
TRID Acceptable Broker Submissions Booklet EQUAL HOUSING LENDER MEMBER FDIC NMLS #478471 WHSL-0022-0116 At Fremont Bank, our goal is to make the submission of your loan applications to us as streamlined
More informationTILA RESPA Integrated Disclosures
TILA RESPA Integrated Disclosures Jimmy Vuong Branch Relations Manager jvuong@afncorp.com Rev. 03/22/2017 American Financial Network, Inc. All Rights Reserved. The Beta is Open Please see Encompass Newsflash
More informationTILA-RESPA Integrated Disclosure Rule FAQs for Wholesale Brokers
TILA-RESPA Integrated Disclosure Rule FAQs for Wholesale Brokers DEFINITIONS AND ACRONYMS TRID: TILA-RESPA Integrated Disclosure Know Before You Owe Rule, text of the rule and more information available
More informationTILA-RESPA Integrated Disclosures (TRID) FAQs
TILA-RESPA Integrated Disclosures (TRID) FAQs On July 21, 2015, the Consumer Financial Protection Bureau (CFPB) published the final rule to delay the effective date of the TILA-RESPA Integrated Disclosure
More informationReference Guide: Loan Estimate (LE) TILA- RESPA Integrated Disclosure (TRID) Rule Requirements
Reference Guide: Loan Estimate (LE) TILA- RESPA Integrated Disclosure (TRID) Rule Requirements The purpose of this document is to provide a reference guide for the Loan Estimate (LE) TILA-RESPA Integrated
More informationTRID. Quick Compliance Guide T I L A-RESPA INTEGRAT E D DISCLOSURES Temenos USA. All rights reserved
TRID T I L A-RESPA INTEGRAT E D DISCLOSURES Quick Compliance Guide 09.01.2015 2015 Temenos USA. All rights reserved w: temenos.com/tricomply p: 205.991.5636 e: usainfo@temenos.com While the publisher and
More informationTRID October 3, 2015!
TRID October 3, 2015! Purpose This announcement includes the following topics: Consumer Financial Protection Bureau (CFPB), Truth-in-Lending and RESPA Integrated Disclosures (TRID). Policy It is MSI Policy
More informationRESPA/TILA Integration
RESPA/TILA Integration 1 Presented by: Richard Hogan, Vice President & Associate General Counsel Tracy Pandolfo, Director Agent Services Agenda Basics: Why We re Here Final Rule The New Forms Evaluating
More informationThe new Loan Estimate Form integrates and replaces the existing RESPA Good Faith Estimate and the initial Truth in Lending forms.
The Consumer Financial Protection Bureau s (CFPB) integrated mortgage disclosure rule will be effective August 1, 2015. This rule consolidates four existing disclosures required under Truth-in-Lending
More informationTILA-RESPA Integrated Disclosure (TRID) Rule a.k.a. Know Before You Owe. with New Haven Middlesex Association of REALTORS
TILA-RESPA Integrated Disclosure (TRID) Rule a.k.a. Know Before You Owe with New Haven Middlesex Association of REALTORS July 16, 2015 Jeremy Potter, General Counsel and Chief Compliance Officer, Norcom
More informationTRID: TILA-RESPA Integrated Disclosures Rules and Procedures Overview
TRID: TILA-RESPA Integrated Disclosures Rules and Procedures Overview Disclaimer Information included is intended for general information purposes only and is current as October 2, 2015. It should not
More informationWhat Real Estate Agents/Brokers Need to Know: Know Before You Owe or the TILA RESPA Integrated Disclosure (TRID) Rule.
What Real Estate Agents/Brokers Need to Know: Know Before You Owe or the TILA RESPA Integrated Disclosure (TRID) Rule Presented by Overview Know Before You Owe (the TILA RESPA Integrated Disclosure (TRID)
More informationComparison of 2010 RESPA-TILA Disclosure Rules to TILA RESPA Integrated Disclosure Rules
Comparison of 2010 RESPA-TILA Disclosure Rules to TILA RESPA Integrated Disclosure Rules Covered Transactions Exemptions Title of Instructions for completion of Delivery of Electronic delivery Federally
More informationTILA RESPA Integrated Disclosure (TRID) Doing Business with NewLeaf
TILA RESPA Integrated Disclosure (TRID) Doing Business with NewLeaf Presented By Marti Tromley EVP, Chief Risk Officer mtromley@newleafwholesale.com The information contained herein is intended as informational
More informationTILA/RESPA Integrated Disclosure Rule
TILA/RESPA Integrated Disclosure Rule Solving the Puzzle July 22, 2015 Presented by: Gary D. Clark, CMB Chief Operating Officer Sierra Pacific Mortgage Webinar All lines will be muted You can type your
More informationCFPB- Getting Ready for NEW Real Estate Closing Procedures. Ruth Dillingham, Special Counsel First American Title Insurance Company April 17, 2014
CFPB- Getting Ready for NEW Real Estate Closing Procedures Ruth Dillingham, Special Counsel First American Title Insurance Company April 17, 2014 1 Supervision of Third Party Vendors CFPB Bulletin April
More informationTRID FAQs: Payment Columns and the Black Hole
TRID FAQs: Payment Columns and the Black Hole Suzanne Garwood, Associate General Counsel Topics Payment Table Columns Index ARMs and Four Columns What if? The Black Hole What is it? What if? 2 Payment
More informationThe Integrated Disclosures Rule Part A: Introduction to the Integrated Disclosures Rule... 5 Topic 1: Consolidated Disclosures...
SA PL M E Contents The Integrated Disclosures Rule... 4 Part A: Introduction to the Integrated Disclosures Rule... 5 Topic 1: Consolidated Disclosures... 5 Topic 2: Integrated Disclosures Requirements...
More informationSection 12.1: Regulation Z Mortgage Disclosure Improvement Act (MDIA) Policy
Section 12.1: Regulation Z Mortgage Disclosure Improvement Act (MDIA) Policy Background SecurityNational Mortgage Company (SNMC) shall comply with the Housing and Economic Recovery Act of 2008 (HERA) which
More informationTHE CLOSING DISCLOSURE
THE CLOSING DISCLOSURE Coverage: Most Closed-End Consumer Mortgages Not HELOCs, reverse mortgages or mobile home loans not attached to real property Agency/Citation: Consumer Financial Protection Bureau
More informationTRID. Old vs New Comparison of TILA/RESPA Integrated Disclosure Changes for Real Estate Agents. Copyright 2015 Go2Training Consultants, LLC.
TRID Old vs New Comparison of TILA/RESPA Integrated Changes for Real Estate Agents Old vs New Comparison of the TILA/RESPA Integrated Changes Good Faith Estimate Loan Estimate The GFE and Initial TIL are
More informationReady. Set. know. Understanding TILA-RESPA Integrated Disclosure (TRID)
Ready. Set. know. Understanding TILA-RESPA Integrated Disclosure (TRID) How our competition is handling TRID. Relying on 3rd party vendors to provide material Communicating what we need to know through
More informationTRID TILA RESPA Integrated Disclosures. Presented by David Luna
TRID TILA RESPA Integrated Disclosures Presented by David Luna Thank you I d like to thank the many sources of information: the Attorney s, Creditors, Title, Credit providers and the CFPB for the information
More informationDISCLOSURE DELIVERY TIMELINE
DISCLOSURE DELIVERY TIMELINE DISCLOSURE INITIAL LOAN ESTIMATE REVISED LOAN ESTIMATE CLOSING DISCLOSURE TIMING Within 3 business days from receipt of the application 4 business days before consummation
More informationThe TILA-RESPA Integrated Disclosure (TRID) Rule. Compiled by: 110 Title, LLC
The TILA-RESPA Integrated Disclosure (TRID) Rule Compiled by: 110 Title, LLC 1 I. Introductory Note The Dodd-Frank Wall Street Reform Act and Consumer Protection Act of 2010 (Dodd-Frank), ushered in the
More informationThe CFPB s TILA-RESPA Integrated Disclosure Rule: What You Need to Know for October 3rd. Paul Bugoni, Esq. Stewart Title Guaranty Company New York, NY
The CFPB s TILA-RESPA Integrated Disclosure Rule: What You Need to Know for October 3rd by Paul Bugoni, Esq. Stewart Title Guaranty Company New York, NY 1 2 The CFPB s TILA-RESPA Integrated Disclosure
More informationCFPB: The New Closing Process
CFPB: The New Closing Process Course Objective: Relate the new CFPB Rules to what the real estate transaction process could look like after August 1, 2015 (CFPB revised date: October 3, 2015) INTRODUCTION
More informationIntegrated Disclosure Vocabulary List. Term Definition as of 8/1/2015 Adjustments and Other Credits
Integrated Disclosure Vocabulary List Term Definition as of 8/1/2015 Adjustments and Other Credits Application (triggering RESPA and TILA early disclosures) Included in this is the total amount of all
More informationThe WAIT IS OVER. THE ANXIETY BEGINS. New RESPA-TILA Mortgage Disclosure Forms
The WAIT IS OVER. THE ANXIETY BEGINS. New RESPA-TILA Mortgage Disclosure Forms Holly Spencer Bunting K&L Gates LLP 1601 K Street NW Washington, DC 20006 (202) 778-9027 holly.bunting@klgates.com Phillip
More informationTRID. Acceptable Broker Submissions Booklet WHSL EQUAL HOUSING LENDER MEMBER FDIC NMLS #478471
TRID Acceptable Broker Submissions Booklet EQUAL HOUSING LENDER MEMBER FDIC NMLS #478471 WHSL-0022-1015 As Fremont Bank transitions to the new Rule, our goal is to make the submission of your loan applications
More informationTRID: THE BUCKET CHALLENGE
TRID: THE BUCKET CHALLENGE 2015 Temenos USA, Inc. All rights reserved. Leah M. Hamilton Chief Compliance Officer TriComply Services WHAT YOU WILL LEARN Good faith Changed circumstance The Tolerance Buckets
More informationTips for Implementing the TILA-RESPA Integrated Disclosure rule
Tips for Implementing the TILA-RESPA Integrated Disclosure rule To support your preparation efforts when implementing the TILA-RESPA Integrated Disclosure (TRID) rule effective for applications dated on
More informationCFPB Integrated Mortgage Disclosure Final Rule
CFPB Integrated Mortgage Disclosure Final Rule Current Status of the New Rule Mary Schuster Chief Product Officer - RamQuest The Regulatory Reform Ecosystem Meet the CFPB Mission Statement o To make markets
More informationTILA / RESPA Integration
The Times, They Are A-Changing (Again)! presented by Jack Konyk Executive Director, Government Affairs OwnOK The Future of Oklahoma Real Estate Feb. 12, 2015 Petroleum Club Oklahoma City, OK 2 Upcoming
More informationThe TRID Process for Wholesale Lending
The TRID Process for Wholesale Lending Michelle McLaughlin 2015 CMG Financial, All Rights Reserved. CMG Financial is a registered trade name of CMG Mortgage, Inc., NMLS #1820 in most, but not all states.
More informationAdvertising, Consumer protection, Credit, Credit unions, Mortgages, National banks,
12 CFR part 1026 Advertising, Consumer protection, Credit, Credit unions, Mortgages, National banks, Recordkeeping and recordkeeping requirements, Reporting, Savings associations, Truth in lending. Authority
More informationThe New Mortgage Disclosure Forms: Know the Rule
The New Mortgage Disclosure Forms: Know the Rule 10:15 11:15 a.m. Phillip L. Schulman, Esq., Partner, K&L Gates LLP THE WAIT IS OVER. THE ANXIETY BEGINS. New RESPA-TILA Mortgage Disclosure Forms Phillip
More informationContents. Basics of the Integrated Mortgage Disclosures Rule...3. Closing Disclosure Sample...4. Closing Disclosure Delivery Calendar Examples...
Contents Basics of the Integrated Mortgage Disclosures Rule...3 Closing Disclosure Sample...4 Closing Disclosure Delivery Calendar Examples...9 Basics of the Integrated Mortgage Disclosures Rule What
More informationFINALLY HERE TILA-RESPA INTEGRATED DISCLOSURE FORMS
TRIPLE PLAY CONVENTION FINALLY HERE TILA-RESPA INTEGRATED DISCLOSURE FORMS December 7, 2015 Phillip L. Schulman K&L Gates LLP 1601 K Street NW Washington, DC 20006 (202) 778-9027 phil.schulman@klgates.com
More informationTIL/RESPA Final Rules on Integrated Mortgage Disclosures
TIL/RESPA Final Rules on Integrated Mortgage Disclosures CLAconnect.com Disclaimers The information contained herein is general in nature and is not intended, and should not be construed, as legal, accounting,
More informationHERE S. TRID. ROBERT E. PINDER (904) ACC Quick Hit -- Truth-in-Lending Act/RESPA Integrated Disclosures Rule June 18, 2015
HERE S. TRID ACC Quick Hit -- Truth-in-Lending Act/RESPA Integrated Disclosures Rule June 18, 2015 ROBERT E. PINDER rpinder@rtlaw.com (904) 346-5551 HERE S. TRID 2 COUNTDOWN TO TRID TRID Goes into Effect
More informationCFPB: The New Closing Process
CFPB: The New Closing Process Course Objective: Relate the new CFPB Rules to what the real estate transaction process could look like after August 1, 2015 INTRODUCTION (10-12 minute segment) TEACHING OBJECTIVE:
More informationFAR/BAR Changes Resulting from the New CFPB Rules What you Need to Know If Your Real Estate Deal MAY Close After October 3, 2015
FAR/BAR Changes Resulting from the New CFPB Rules What you Need to Know If Your Real Estate Deal MAY Close After October 3, 2015 By Melissa Jay Murphy, Esq. General Counsel Attorneys Title Fund Services,
More informationFREQUENTLY ASKED QUESTIONS (FAQ) FOR IMPLEMENTING THE TILA-RESPA INTEGRATED DISCLOSURE RULE (TRID)
Best Practices FREQUENTLY ASKED QUESTIONS (FAQ) FOR IMPLEMENTING THE TILA-RESPA INTEGRATED DISCLOSURE RULE (TRID) SUMMARY With the upcoming implementation of the Truth in Lending (TILA)/Real Estate Settlement
More informationReasons for Change. Are You Ready for the Regulation Z & RESPA Changes. Past, Present & Future Changes
Are You Ready for the Regulation Z & RESPA Changes Community Bankers Association of Illinois Annual Convention September 26, 2009 Presented by: Young & Associates, Inc. 1 Past, Present & Future Changes
More informationClosing Disclosure August 1, CFR
Closing Disclosure August 1, 2015 12 CFR 1026.38 Agent Questions for Lender Clients Who will prepare the Closing Disclosure (CD) Form? How will Agents coordinate with the lender to prepare the Closing
More informationCFPB-TRID Frequently Asked Questions June 15, 2015
CFPB-TRID Frequently Asked Questions June 15, 2015 Contents TILA-RESPA Integrated Disclosure Rule... 2 Effective Date(s)... 2 Impacted People, Property & Transaction Types... 2 Financing Type... 4 Seller
More informationBAI Learning & Development Webinar Q&A TILA-RESPA Integration Part 2 A New Way to Disclose
BAI Learning & Development Webinar Q&A TILA-RESPA Integration Part 2 A New Way to Disclose 1. Does the intent to proceed have to be received by all Applicants or just an applicant? Answer: The regulation
More informationTRID Update: 6 Months In, Areas of Concern and Uncertainty
TRID Update: 6 Months In, Areas of Concern and Uncertainty New Jersey Bankers Association prycompliance@hotmail.com 0 0 of of 6674 Clarifications Coming CFPB announced upcoming Proposed Rule in April 28,
More informationTRID TILA RESPA Integrated Disclosure. September 29, 2015 Select Partner Process Overview
TRID TILA RESPA Integrated Disclosure September 29, 2015 Select Partner Process Overview 1 Objectives Important Definitions Product Delivery SP Workflow Overview CMG Drawn Docs Process SP Drawn Docs Process
More informationWELCOME! Are You Ready for TRID?
1 WELCOME! www.grantsimon.com Are You Ready for TRID? 2 Dodd Frank the CFPB & You Featuring TRID TRID TILA-RESPA INTEGRATED DISCLOSURE 3 Ready For It New Jargon Lender Borrower Closing GFE & TIL HUD 1
More informationWELCOME!
WELCOME! www.grantsimon.com Are You Ready for TRID? Dodd Frank the CFPB & You Featuring TRID TRID TILA-RESPA INTEGRATED DISCLOSURE Ready For It New Jargon Lender Borrower Closing GFE & TIL HUD 1 & TIL
More informationIntroduction to the TILA-RESPA Integrated Disclosure Rule TRID
Introduction to the TILA-RESPA Integrated Disclosure Rule TRID October 3, 2015 Aaron Mason NMLS 54707 Mortgage Loan Officer 859-230-4628 AaronMason@homeserviceslending.com AaronMason.RectorHaydenMortgage.com
More informationTRID (TILA-RESPA Integrated Disclosures) Presented by:
TRID (TILA-RESPA Integrated Disclosures) Presented by: What is TRID? TRID will eliminate the use of the good faith estimate, truth in lending disclosures, and HUD-1 Settlement Statement. They will now
More informationForensic Review Report
Forensic Review Report Prepared by Aequitas Borrower: John Smith Date: 7/9/2009 Copyright 2009 MHI. All Rights Reserved. 2 of 19 TABLE OF CONTENTS Review Letter... 4 Forensic Review Summary... 5 Forensic
More informationFebruary 2016 FEBRUARY Sunday Monday Tuesday Wednesday Thursday Friday Saturday. CD is placed in the mail IF DELIVERED BY OVERNIGHT MAIL...
DELIVERY METHODS & TIMING CHEAT SHEET IF DELIVERED BY MAIL... Closing Disclosure (CD) is sent to borrower in the mail 3 day mailing rule applies for the receipt of the disclosure Then 3 day waiting period
More informationDelivered in partnership with your local title agency
Delivered in partnership with your local title agency titlesinsured 1.877.439.4910 About this Manual In an effort to provide a thorough condensed training reference, this manual was created based on the
More informationTILA RESPA Integrated Disclosure (TRID) Closing Disclosure Instructions Page 1 LHFSCorrespondent.com (972)
Page 1 The date this disclosure is delivered to the consumer. The date of consummation. The date when the loan amount will be paid, either to the consumer and seller for purchase loans, or to the consumer
More informationCorrespondent Procedures. rev. 8/3/16
Correspondent Procedures rev. 8/3/16 1 Website www.mmcitpo.com AUS Run Requests Definition of an application Fees Registration/Rate Lock The Loan Estimate Submission Checklists TBDs LE/CD Revision Requests
More informationThe CFPB s New Mortgage Disclosures
The CFPB s New Mortgage Disclosures Benjamin K. Olson March 10, 2015 Key Changes Effective August 1, 2015: GFE and initial TIL replaced with the Loan Estimate The items constituting an application are
More informationTILA RESPA Integrated Disclosure ~ Closing Disclosure (CD) ~
Click for audio recording of training TILA RESPA Integrated Disclosure ~ Closing Disclosure (CD) ~ Fowler Williams President Crescent Mortgage Company 1 Question and Answers Email fwilliams@crescentmortgage.net
More informationLoan Estimates. with the following requirements: Estimate SMF SMF SMF
Loan Estimates with the following requirements: Estimate SMF SMF SMF Please follow the directions below when completing the Initial Loan Application and Disclosure processes. e e cc e and Locked LE, including
More informationExecutive Summary of the 2017 TILA- RESPA Rule
1700 G Street NW, Washington, DC 20552 July 7, 2017 Executive Summary of the 2017 TILA- RESPA Rule On July 7, 2017, the Consumer Financial Protection Bureau (Bureau) issued a final rule (2017 TILA-RESPA
More informationNEW INTEGRATED DISCLOSURES EFFECTIVE AUGUST 1, May 7, 2015
NEW INTEGRATED DISCLOSURES EFFECTIVE AUGUST 1, 2015 from a program presentation made by Nellie Woodward at the Texas Land and Mortgage/TLDA membership meeting held on May 7, 2015 The following BRIEFLY
More informationWHOLESALE Good Faith Estimate Compliance Manual
WHOLESALE Good Faith Estimate Compliance Manual Understanding the 2010 GFE Compliance Department 2/2/2015 2015 Pacific One Lending. http://www.nmlsconsumeraccess.org. Rates, fees and programs are subjected
More informationOur Industry Today TRID AND BEYOND. RDH Education Services. Presented by RDH Education Services
RDH Education Services Our Industry Today TRID AND BEYOND Presented by RDH Education Services RDH Education Services can be contacted at: 4361 Technology Dr, Unit A, Livermore, CA 94551 877-734-4347 info@rdheducation.com
More informationUnderstanding the New Truth in Lending Act Disclosure Rules Effective July 30 th
Understanding the New Truth in Lending Act Disclosure Rules Effective July 30 th July 15, 2009 The home mortgage industry is abuzz with concerns about new disclosure rules under the Truth in Lending Act
More informationMake Compliance Relaxing
Make Compliance Relaxing Sit back, relax. The webinar will begin at the top of the hour. While you are waiting, you may download the presentation outline at: QuestSoft.com/TRID-Webinar Please stand by.
More informationFacing Today s Real Estate Regulations
Proudly Sponsored by Facing Today s Real Estate Regulations Presented by Don Braspenninckx Day, June 11, 2016 1:30 p.m. 1 Introduction Numerous regulatory changes in the real estate industry within last
More informationComment Call (12-14)
Comment Call (12-14) To: From: All Affiliated Credit Union CEOs Veronica Madsen Director of Regulatory Affairs Date: August 28, 2012 RE: CFPB Combined TILA/RESPA Disclosures Summary The Dodd-Frank Wall
More informationUnderstanding CFPB Rules CONSUMER FINANCIAL PROTECTION BUREAU
Understanding CFPB Rules CONSUMER FINANCIAL PROTECTION BUREAU The Consumer Financial Protection Bureau The CFPB is a new federal agency Created by Dodd Frank Wall Street and Consumer Protection Act Dodd
More informationTRID TILA-RESPA Integrated Disclosures. FOR INTERNAL DISTRIBUTION ONLY Please refer to Disclaimer & Legal Notice on the last page.
TRID 2015 TILA-RESPA Integrated Disclosures FOR INTERNAL DISTRIBUTION ONLY Please refer to Disclaimer & Legal Notice on the last page. 2 Today s Agenda A look at our presentation agenda & goals for today
More informationBROWN, FOWLER & ALSUP A Professional Corporation Attorneys at Law MEMORANDUM. RESPA 101 The New Good Faith Estimate (GFE) Rules
BROWN, FOWLER & ALSUP A Professional Corporation Attorneys at Law J. Alton Alsup 10333 Richmond, Suite 860 Telephone 713/468-0400 Board Certified in Residential Real Estate Law Texas Board of Legal Specialization
More informationBuydown FAQs. Version: 1.0 (May, 2017) What types of buydowns are there? Regulation Z only contemplates the following types of buydowns:
Buydown FAQs Disclaimer: This document provides answers to frequently posed questions to Docutech concerning buydowns. Nothing in this document is to be construed as legal advice. Readers are advised to
More informationCompensation paid directly by the consumer and/or the creditor to a loan originator other than an employee of the creditor
This guide to the Closing Disclosure form is not a comprehensive how to guide. Instead, it is intended to highlight certain areas of the form that require some detailed and difficult input. This guide
More informationConsumer Financial Protection Bureau Rule
Consumer Financial Protection Bureau Rule Presented by Jerry T. Gorman Attorneys Title Guaranty Fund, Inc. Champaign CFPB Rule Consumer Financial Protection Bureau (CFPB) Came into being July 2011 Created
More informationFREDDIE MAC Q&A: APPRAISER INDEPENDENCE REQUIREMENTS
FREDDIE MAC Q&A: APPRAISER INDEPENDENCE REQUIREMENTS Appraiser Independence Requirements Scope of Coverage 1. What loans are affected by the Appraiser Independence Requirements (AIR) 2. Does AIR apply
More informationTRID TILA RESPA Integrated Disclosures
Experience Extraordinary TRID TILA RESPA Integrated Disclosures July 16, 2015 Changed Circumstances: Revised Loan Estimates and Revised Closing Disclosures Kara Lamphere Changed Circumstances The reasons
More informationTILA RESPA Integrated Disclosure
FEBRUARY 7, 2014 TILA RESPA Integrated Disclosure H-24(G) Mortgage Loan Transaction Loan Estimate Modification to Loan Estimate for Transaction Not Involving Seller Model Form This is a blank model Loan
More informationTRID (TILA-RESPA ITNEGRATED DISCLOSURE RULE) FAQ
TRID (TILA-RESPA ITNEGRATED DISCLOSURE RULE) FAQ This frequently asked questions in this document have been categorized into the following three sections: Loan Estimate Closing Disclosure Miscellaneous
More informationThe New Loan Estimate & Closing Disclosure Explained. Know before you close.
Know before you close. The New Loan Estimate & a Closing Disclosure Explained A look at the different sections of each new form and explanations of each page. 2015 Chicago Title Know before you close.
More informationInvestor R - Jumbo Product TRID Early Issues Update # 3
Investor R - Jumbo Product TRID Early Issues Update # 3 March 7, 2016 The purpose of this communication is to update you on Investor R s policy regarding the acceptance of loans with certain Loan Estimate
More informationNew Mortgage Servicing Rules
Aldrich & Bonnefin New Mortgage Servicing Rules Robert K. Olsen, Esq. Disclaimer This presentation is intended solely for educational purposes to provide you general information about laws and regulations
More informationRESPA REFORM TRAINING Effective January 1, FOR MORTGAGE PROFESSIONALS ONLY Rev 1, 12/29/09
RESPA REFORM TRAINING Effective January 1, 2010 OVERVIEW In November 2008, HUD published its final rule amending Regulation X of the Real Estate Settlement Procedures Act (RESPA). The final rule includes
More informationLOAN ESTIMATE (LE) CLOSING DISCLOSURE (CD) MISCELLANEOUS QUESTIONS
Florida Capital Bank Mortgage (FCBM) has put together this Frequently Asked Question (FAQ) document with key questions and topics regarding and its implementation at FCBM. We have categorized the Q&A s
More informationTHE TRID RULE: IMPACT AND CONSEQUENCES ON THE RESIDENTIAL MORTGAGE LENDING MARKET. Christopher W. Smart
THE TRID RULE: IMPACT AND CONSEQUENCES ON THE RESIDENTIAL MORTGAGE LENDING MARKET Christopher W. Smart Introduction and Background Residential mortgage lenders have long been required to disclose to their
More informationTruth in Lending / RESPA Regulatory Changes
Steve H. Powell & Company Truth in Lending / RESPA Regulatory Changes Truth in Lending and RESPA Update Note: This publication is not offered as legal advice. Readers should seek legal counsel for advice
More informationFEES & CHARGES LIST AS OF 10/30/2015
FEES & CHARGES LIST AS OF 10/30/2015 SPL = Service Providers List VP = Variations Permited DISCLAIMER: This document contains proprietary information for Platinum Mortgage internal staff use only. All
More informationTRID TOPICS Forms The Closing Disclosure (CD)
TRID TOPICS VIII June 8, 2015 TRID TOPICS Forms The Closing Disclosure (CD) WHAT IS THE CLOSING DISCLOSURE AND HOW DOES IT DIFFER FROM TODAY: The Closing Disclosure, also referenced as the CD, under the
More informationPrior to Closing Wholesale
Closing Section 5 Prior to Closing Wholesale ------------------------------------------------------------ 5.2 Closing the Loan Wholesale ---------------------------------------------------------- 5.2 Title
More informationWhen will this happen? Implementation Date. Applications taken on or after. August 1 st, 2015
Let the Fun BEGIN!! When will this happen? Implementation Date Applications taken on or after August 1 st, 2015 Closing Disclosure Elizabeth A. Daniel, Continental Title Company David A. Townsend, Esq,
More informationProgram Eligibility Guide Portfolio Conforming/Jumbo Products: Conforming PA51, PA71 Jumbo PA51J, PA71J
Program Eligibility Guide Portfolio Conforming/Jumbo Products: Conforming PA51, PA71 Jumbo PA51J, PA71J [Type text] Table of Contents 1. Portfolio Conforming/Jumbo Product Matix and Product Codes...3 2.
More informationPer Diem Interest. COMPLYING WITH CALIFORNIA FINANCIAL CODE 50204(o) and CALIFORNIA CIVIL CODE
Per Diem Interest COMPLYING WITH CALIFORNIA FINANCIAL CODE 50204(o) and CALIFORNIA CIVIL CODE 2948.5 Per Diem Interest What is per diem interest? Interest payment made by a borrower(s) on the money loaned
More informationClosing Disclosure (CD) Communicating with Creditors Owner s Title Insurance Premium
Frequently Asked Questions CFPB s TILA-RESPA Integrated Disclosure (TRID) Rule To use the index, click on a topic below to be taken to that topic location in the document. Section 1: Section 2: Section
More informationTRID Update, Liability, and Cures. Presented By Richard Horn Richard Horn Legal PLLC
TRID Update, Liability, and Cures Presented By Richard Horn Richard Horn Legal PLLC The TRID Rule Past, Present, Future Richard Horn Legal PLLC Dodd-Frank Act sections 1032(f), 1098, and 1100A directed
More informationHUD s New RESPA Rule
1300 Nineteenth Street, NW Fifth Floor Washington, DC 20036 202.628.2000 www.wbsk.com HUD s New RESPA Rule November 24, 2008 On November 17, 2008 the United States Department of Housing and Urban Development
More informationNew RESPA Rule FAQs. (New items are in bold)
New RESPA Rule FAQs (New items are in bold) Table of Contents General... 3 GFE... 5 GFE General... 5 GFE Seller paid items... 9 GFE Interest rate expiration... 9 GFE Expiration... 10 GFE Denial... 10 GFE
More information