TILA RESPA Integrated Disclosure ~ Closing Disclosure (CD) ~

Transcription

1 Click for audio recording of training TILA RESPA Integrated Disclosure ~ Closing Disclosure (CD) ~ Fowler Williams President Crescent Mortgage Company 1

2 Question and Answers Subject: TRID 7/6/2015 This is not legal advice Crescent Mortgage Company TRID Closing Disclosure 2

3 Closing Disclosure Basics Like the LE Combines initial TIL and GFE, CD combines the final TIL and HUD-1 Effective for applications taken on or after 8/1/2015 Applications prior to 8/1/ 2015 will continue to close using HUD-1 Providing the CD CD must be received by the consumer at least 3 business days before consummation Additional 3 business day waiting period if: The APR becomes inaccurate (current tolerances apply, generally 1/8 of a percent or 1/4 of a percent for irregular loans); The loan product changes; or A prepayment penalty is added Mailbox Rule Applies LE and CD Disclosure considered received three business days after delivery or mailing Can be trumped by evidence of receipt 7/6/2015 This is not legal advice Crescent Mortgage Company TRID Closing Disclosure 3

4 Closing Disclosure Timing E- Sign: Disclosures may be delivered electronically by Disclosures Received date in compliance with E-Sign. If there is no proof that borrower received, mailbox rule applies (assumed to have received in 3 days). Three day timing is measured in days, not hours. Closing Disclosure must be received 3 days prior to settlement, not 72 hours prior to settlement. If a federal holiday falls in the three day period add one day to disclosure delivery day. 7/6/2015 This is not legal advice Crescent Mortgage Company TRID Closing Disclosure 4

5 E Sign Borrower must consent prior Borrower must be able to withdraw consent Evidence of : Consent Delivery log Mailbox rule applies Assumed delivered in 3 days Can shorten timelines with proof of receipt Must comply with ESIGN and EUTA 5

6 Closing Disclosure Page 1 Header Loan Terms Projected Payments Costs at Closing 6

7 Closing Disclosure Page 1 Header Blank Completed - Purchase 7

8 Closing Disclosure Page 1 Loan Terms Blank Completed - Purchase 8

9 Closing Disclosure Page 1 Projected Payments Blank Completed 9

10 Closing Disclosure Page 1 Costs at Closing Blank Completed Alternative Version of CD Refinance (transaction without a seller) 10

11 Closing Disclosure Page 2 Loan Costs Origination Services Borrower Did Not Shop For Services Borrower Did Shop For Other Costs Taxes and Government Fees Prepaids Initial Escrow Payment Other Itemization No HUD-1 line #s Alphabetical Order Same fee names 11

12 Closing Disclosure Page 2 Loan Costs Blank 12

13 Closing Disclosure Page 2 Loan Costs Completed 13

14 Closing Disclosure Page 2 Other Costs Blank 14

15 Closing Disclosure Page 2 Other Costs Completed 15

16 Closing Disclosure Page 3 Calculating Cash to Close Summaries of Transaction 16

17 Closing Disclosure Page 3 Calculating Cash to Close Blank Completed 17

18 Closing Disclosure Page 3 Summaries of Transactions Blank 18

19 Closing Disclosure Page 3 Summaries of Transactions Completed 19

20 Closing Disclosure Page 3 Payoffs and Payments Alternative CD for transaction without a seller 20

21 Closing Disclosure Page 3 Calculating Cash to Close Alternative CD for transaction without a seller 21

22 Closing Disclosure Page 4 Disclosure(s) Adjustable Payment Table (AP) Adjustable Interest Rate Table (AIR) 22

23 Closing Disclosure Page 4 Loan Disclosures 23

24 Closing Disclosure Page 5 Loan Calculations Disclosures Questions? Contact Information Optional Signature Line 24

25 Closing Disclosure Page 5 Loan Calculations Questions 25

26 Closing Disclosure Page 5 Other Disclosures Disclosure below must be included if not using signature line. 26

27 Closing Disclosure Page 5 Contact Information 27

28 Closing Disclosure Page 5 Contact Information Alternative Contact Information Refinance (No seller) 28

29 Thank You Fowler Williams, CMB President Crescent Mortgage Company (800) Subject: TRID Peachtree Dunwoody Rd NE 600 Embassy Row, Ste. 650 Atlanta, GA