When will this happen? Implementation Date. Applications taken on or after. August 1 st, 2015

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1 Let the Fun BEGIN!!

2 When will this happen? Implementation Date Applications taken on or after August 1 st, 2015

3 Closing Disclosure Elizabeth A. Daniel, Continental Title Company David A. Townsend, Esq, NTP Agents National Title Insurance

4 New Form O Closing Disclosure O Replaces current HUD-1 and final TIL O Five pages long

5 What types of transactions are exempt? O Home Equity lines of credit O Reverse Mortgages O Mortgages secured by a mobile home that is not attached to real property O Loans made by a creditor who makes five or fewer mortgages in a year. O Cash Transactions O Commercial Transactions

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7 Closing Information

8 Loan Terms

9 Page 1 Section: Projected Payments

10 : O Estimated Escrow Includes Taxes and Insurance of $ O Estimated Taxes, Insurance AND Assessments includes Homeowner s Association Dues.

11 Costs at Closing O Provides a quick snap shot of the next two pages of the Closing Disclosure for the borrower ONLY.

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13 Notable Changes O No longer called a HUD or Settlement Statement O Removal of our 700, 800, 900, etc. sections O O O O Each alphabetical section will have all of the fees alphabetically in order. Fees are now itemized No more rolling up Separate columns for Paid Before Closing fees. No more POCL, POCB, POCS At the TOP of each section the Borrowers total is BOLDED and includes the Before Closing fees in amount.

14 Loan Costs CFPB removed the verbiage from Tolerances to Variance A. Origination Charges 0% Variance B. Services Borrower Did Not Shop For 10% Variance C. Services Borrower Did Shop For Costs can change D. Total Loan Costs

15 Other Costs (E-H) E. Recording Fees F. Prepaids O O O O Homeowners Insurance Mortgage Insurance Prepaid Interest Property Taxes G. Initial Escrows H. Other O O O O O HOA/Condo fees Home Inspection Home Warranty Real Estate Commission Title-Owners Title Insurance (Optional)

16 Taxes and Other Government Fees O Per the CFPB Creditors should disclose the name of the entity assessing the transfer tax, even if that is different from the payee of the check cut by the settlement agent. The governing authority assessing the transfer tax must be disclosed, along with the amount paid by consumer, the borrower, seller and others.

17 Owners Title Insurance Optional O The Optional label still applies for buyerpaid insurance O If the seller pays, option phrase is eliminated

18 Other Costs (J) O All of the Borrowers BOLDED amounts are totaled in Section J O Seller Columns are totaled O Paid by Others are totaled

19 Lender Credits

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21 Calculating Cash to Close O Comparison of the Loan Estimate and Final Closing Disclosure

22 Summaries of Transactions

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32 Confirming Receipt O Title software will be adding a FINAL Receipt/Signature line O Currently there is not a final signature line on the Closing Disclosure

33 Who provides the Closing Disclosure 3 days before closing? O According to the final ruling the LENDER/CREDITOR is responsible for delivering the Closing Disclosure form to the consumer O BUT the lender/creditor may USE settlements agents to deliver the Closing Disclosure as well. O Chase, Citi Bank, Wells Fargo and Bank of America have announced they will complete and send the CDF to the consumer.

34 When does the 3 day start? O Timing requirements on different delivery methods O O O O In person: received on the day provided Mail (USPS): received 3 business days after placed in mail unless evidence that consumer received it sooner received 3 business days after sent unless evidence that consumer received it sooner (Read receipt is not enough) UPS or FedEx received 3 days business days after sent unless signed and return receipt signature is received sooner

35 What would trigger a NEW 3 day waiting period before you can close? O If the APR changes above 1/8 of a percent on most loans O Changes in the loan product O The creditor adds a prepayment penalty to the loan

36 How do we show our premium

37 From Page # 1795 of the Final Rule and Interpretation O Section (f)(2) and (3) requires disclosure of the amount the consumer will pay for the lender s title insurance policy.

38 From Page # 1795 of the Final Rule and Interpretation O The amount disclosed for the lender s title insurance policy pursuant to (f)(2) or (3) is the amount of premium without any adjustment that might be made for the simultaneous purchase of the owners policy.

39 From Page # 1802 of the Final Rule and Interpretation O The title insurance premium for a lender s title insurance policy on the full premium rate

40 From Page # 1802 of the Final Rule and Interpretation O The owner s title insurance premium is calculated by taking the full owner s title insurance premium, adding the simultaneous issuance premium for the lender s coverage, and then deducting the full premium for lender s coverage.

41 Owners Title Insurance O Any simultaneous issue discount must be applied to the owner s policy premium (and not the loan policy premium).

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