TRID (TILA-RESPA Integrated Disclosures) Presented by:

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1 TRID (TILA-RESPA Integrated Disclosures) Presented by:

2 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 be combined into one disclosure The Loan Estimate form will be replacing the Good Faith Estimate and Truth In Lending Disclosure and is to be provided at application and re-disclosed as necessary. The Closing Disclosure will be replacing the HUD-1 Settlement Statement and final Truth In Lending Disclosure and must be provided three business days before consummation of the loan. The three business days does not being until the borrower acknowledges receipt of the Closing Disclosure. TRID goes into effect October 3 rd,2015 What is the purpose? The old forms were developed by two different agencies and the information overlaps and the language was inconsistent which often made them confusing for consumers. The new forms will be simplified and easier for consumers to understand.

3 How will TRID affect the closing timeline? For the three business day waiting period, here is an example of how to count the earliest day when consummation (closing) may occur for a purchase or non-rescindable refinance transaction: Monday (This counts as Day 0) Closing disclosure delivered and received by the consumer. Tuesday (This is Day 1). Wednesday (This is Day 2). Thursday (Day 3) Consummation (closing) may occur. Can the Closing Disclosure be re-disclosed after the initial delivery to the consumer without affecting the three-day waiting period? Yes, re-disclosure is permissible for all instances without triggering a new three-day waiting period except for the following: Product Change - Fixed to an ARM, Housing Finance Agency loan switched to standard FHA loan. Change in APR tolerance Increasing.125% or higher for a fixed rate product or.250% or higher for an ARM product; or decreasing.125% or higher for a fixed rate product or.250% or higher for an ARM product and finance charge increased by $100 or more. Addition of a pre-payment penalty (Not applicable for UHM).

4 What do Real Estate Brokers and their Sales Professionals Need to do to Prepare for the TRID Changes? Reanalyze transaction timelines to conform to new requirements for delivery to the borrower of the Closing Disclosure Form. Brokers will need to focus on getting conditions submitted quickly in order to facilitate the issuance of the CD a minimum of 3 business days prior to the expected closing date. What is Affected: Back-to Back-transactions building in contingencies Clearing all other contingencies such as title, liens, property conditions Final Walk-throughs Buyer-Seller agreements that can impact the loan process No last minute changes Property Condition and Price Adjustments: Provide Lender any Buyer-Seller agreements (addendum to sales contract) as early as possible Tailor repair completion date, based on new timeline requirements Walk-through inspections remember the purpose Did the seller complete agreed upon repairs? Make sure to set earlier contract completion and reinspection dates Is the property in the same condition or did anything change? An example would be: House not clean vs. newly torn screens.

5 Interfacing Effectively with Consumers: Work closely with lender and title professionals for consistent information to the borrower. Make sure there are regular updates between the parties Know who to contact and make sure the lender knows who the right contacts are Help the borrower navigate by providing positive support through transaction challenges Don t schedule closing for the last day of the buyer s lease. Don t seek to alter planned closing dates without good advance notice and consideration What is Union Home Mortgage doing to prepare for TRID? Effective June 15 th we implemented a 24 hour waiting period from clear to close to closing and increased that required waiting period by 1 day in each subsequent month. We used this a measuring tool but in no way held up any closings as a result. Union Home Mortgage has developed and will be implementing a Parallel Process which gives our Closing Dept. access to the files much sooner in the process to prepare the CD. This will ensure that as soon as we are able to, the CD can be delivered to the borrower. All disclosures and re-disclosures including the LE & CD will be sent to the borrower electronically by Union Home Mortgage Corp. for e-signature and acknowledgement. E-signing and E-acknowledging will start the clock ticking on the required waiting period's as quickly as possible. The broker will still be responsible for the delivery of the initial application disclosures including the LE to the borrower. We feel the above steps will help prepare everyone to get more comfortable with the new timelines. We will have this process well in hand with business as usual upon the onset of the Mandatory Waiting Period to close set by the CFPB.