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1 CFPB and the Changing Landscape of Real Estate Closings Presented by Powered by Investors Title

2 The only thing constant in life is change. - François de la Rochefoucauld And the CFPB is proof positive!

3 QUICK REVIEW 35+ years RESPA/TILA Dodd-Frank requires consolidation Consumer Finance Protection Bureau (CFPB) to carry out Dodd- Frank

4 ROUND TWO Proposed amendments to 12 CFR contained in the Bureau's notice at 77 FR (Aug. 23, 2012) FINAL RULE expected September, 2013 IMPLEMENTATION within 12 months from Final Rule New Loan Estimate -GFE and TILA out New Closing Disclosure -HUD-11 out Limits closing cost increases Redefines APR Additional Consumer Protections Supervision of Service Providers

5 God grant me the serenity to accept the things I cannot change, the courage to change the things I can, and the wisdom to know the difference. - Reinhard Niebuhr

6 GOOD INTENTIONS Simpler Highlights information consumers need Clear warnings about prepayment penalties and an increase in the loan balance (negative amortization) Requires maintenance of electronic copies so regulators will be able to address compliance questions more easily More time to consider choices Limits on closing cost increases

7 CHEERS The negative becomes self fulfilling, gloom creates more gloom Scientific evidence shows pride in our work makes us happier Embrace the changes to be more secure in your closing future

8 NEW(EST) LOAN ESTIMATE Combines final TILA disclosure/gfe Provided by creditor 3 pages Within 3 days of application Application is defined Can only charge for credit report Revisions only if changed circumstance Charges alphabetical-closing charges under title,, Owners insurance quote standard rate

9 EXAMPLE For an adjustable rate mortgage (ARM) monthly costs today projects the monthly payment as adjusts Brings light to the risk-a a rate now in the low 3%s may increase to 8%, it may not be affordable.

10 APPLICABILITY All closed-end end consumer credit secured by RE Excludes HELOCs and Reverse Mortgages (separate, 1/30/2011 Reg Z rules, Subparts B and C )

11 LOAN ESTIMATE

12 LOAN ESTIMATE-Page 3

13 APPLICATION The submission of a borrower s s financial information in anticipation of a credit decision relating to a federally related mortgage loan, which shall include the borrower s s name, the borrower s s monthly income, the borrower s s social security number to obtain a credit report, the property address, an estimate of the value of the property, and the mortgage loan amount sought

14 SHOPPING LISTS Creditor shall identify the services the consumer is permitted to shop for in the Loan Estimate May include affiliates of lender in list-are you on the lists?

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17 NEW(EST) CLOSING DISCLOSURE Combines final TILA disclosure & HUD-1 Must provide at least 3 days prior to closing (exclusive of Sundays, legal holidays) 5 pages Provided by Lender(7 days) or Settlement Agent Revisions require additional 3 day review Limited exceptions for variance of 3 day rule

18 3 Day Exceptions Consumer and seller agree to changes that affect items disclosed- at or before consummation Amount actually paid by the consumer does not exceed the amount disclosed by more than $100- at or before consummation Event occurs after consummation causing disclosures to become inaccurate solely from payments to a government entity in connection with the transaction-no no later than 30 days after consummation

19 3 Day Exceptions-continued Non-numeric numeric clerical errors-asap but no later than 30 days after consummation Amounts paid by the consumer exceed the amounts specified- creditor must refund excess to the consumer asap but no later than 30 days after consummation, AND creditor provides revised disclosures reflecting refund asap but no later than 30 days after consummation

20 NEW(EST) CLOSING DISCLOSURE EXACT amount to bring to closing Prepayment penalties on Page 1 Balloon Payments on Page 1 Alphabetical charges-closing closing charges under title

21 CLOSING DISCLOSURE

22 CLOSING DISCLOSURE-Pages 3&4

23 CLOSING DISCLOSURE-Page 5

24 LIMITS ON INCREASES Zero Tolerance lenders charges for own services, services by an affiliate, broker, ie. processing and underwriting fees (Loan Estimate Page 2, Section A) charges for services consumer not permitted to shop (Loan Estimate Page 2, Section B) Appraisal, Credit Report, Flood/Tax Service Transfer tax

25 EXCEPTIONS TO 10% CAP Update 3 days prior required Consumer requests change Consumer chose provider Information from application inaccurate (or becomes) Loan Estimate expires Recording Fees

26 NO TOLERANCE RESTRICTION Loan originator required services where the borrower selects his or her own third- party provider; Title services, lender s s title insurance, and owner s s title insurance when the borrower selects his or her own provider; Initial escrow deposit; Daily interest charges; and homeowner s insurance

27 Tolerance Existing RESPA Rules Proposed Integration Rules 0 Tolerance May not exceed fees estimated on the GFE Origination Charges Points Transfer Tax Fees paid to the creditor points, yield spread premium, processing & underwriting fee Transfer Tax Fees paid to broker Fees paid to an affiliate Fees paid to unaffiliated third party if consumer is not allowed to shop 10% Tolerance Individual fees may increase or decrease, but the sum of the charges at settlement may not be greater than ten percent above the sum of the amounts included on the GFE. Required services selected by lender Title Services and lenders title insurance if selected by lender or off list Owner s s title if on list Required services selected by consumer off list Government Recording Charges Fees paid to unaffiliated third party settlement agent if consumer can shop, does not choose one, or chooses one off list provided Recording Fees No Tolerance Fees not subject to any tolerance restriction, can change at settlement and the amount of the change is not limited. Required services selected by consumer Title services and lenders title if selected by consumer and not on list Owners title not on list Initial escrow deposit Daily interest charge Homeowners insurance Prepaid interest Property insurance Escrow Charges paid to third party selected by consumer and not identified by creditor *Provided estimates are consistent with best information available to creditor at time loan estimate is made

28 FINANCE CHARGE Includes title examination, abstract of title, title insurance, property survey, and similar items; preparing loan-related documents, such as deeds, mortgages, and reconveyance or settlement documents; notary and credit report fees; property appraisal or inspections to assess the value or condition of the property prior to closing, including pest-infestation or flood-hazard determination; and amounts required to be paid into escrow or trustee accounts if the amounts would not otherwise be included in the finance charge Also government recording taxes and related fees

29 WHO PROVIDES DISCLOSURE? Creditor solely responsible for the provision of the closing disclosures Alternative: settlement agent may provide a consumer with the disclosures, provided the settlement agent complies with all requirements of (f) as if it were the creditor. Not intended to relieve the creditor s responsibility under TILA and creditor remains responsible to ensure disclosures are provided in accordance with the requirements of (f)

30 SELLER Seller Transaction Coverage The person conducting the settlement shall provide the seller with the disclosures that relate to the seller No later than the day of consummation. Revised disclosures to the seller no later than 30 days after consummation The amount imposed upon the seller for any settlement service shall not exceed the amount actually received by the service provider for that service, except for average charges

31 CAN I CHARGE????? (Insert laugh track) No fee may be imposed on any person, as a part of settlement costs or otherwise, by a creditor or by a servicer for the preparation or delivery of the disclosures, escrow account statements required pursuant to section 10 of RESPA, or other statements required by TILA

32 RECORD RETENTION Creditors must keep such records in an electronic, machine readable format Retain evidence of compliance for three years Retain each completed closing disclosure and all documents related to such disclosures, for five years after settlement.*investors agent contracts keep all title files forever in electronic, machine readable format Machine readable means a format where the individual data elements comprising the record can be transmitted, analyzed, and processed by a computer program, such as a spreadsheet or database program (NOT PDFs)

33 APR REDEFINED Includes almost all up-front costs except charges that are applied after the loan closes, such as late fees or delinquency charges Previously exempted costs like application fees now included

34 THOUGHTS TO PONDER If lender becomes responsible for preparation and delivery of the e final Disclosure Form, what role will settlement agents play? Will settlement agents continue to aggregate information for the Closing Disclosure from other parties outside the realm of the loan l itself i.e. real estate commissions, homeowner s s associations, obtaining payoff of debts, ordering final utility readings, ordering ring surveys, collecting back child support or other government liens and debts? If so, could lender decide to act as the disbursement agent for all loan proceeds, some loan proceeds?

35 THOUGHTS TO PONDER How will the lenders begin to incorporate all of these facets into their daily operations? Consumers look to us to be timely and look to us to handle the transaction an efficient manner, Evans said. If we lose productivity through these new regulations, it will impact production and how we serve our customers. ALTA

36 SPECIFIC ISSUES How often do closing costs change within 3 days of closing? What are the reasons these costs change? What other exemptions to the rule might be warranted to ensure the consumer is not harmed by a delay? What training, increased precalls with lenders, time taken within redisclosures, costs will you have?

37 OTHER CHANGES

38 HIGH COST MORTGAGE PROTECTIONS Effective January 2014 Definition: first mortgage with APR > 6.5 points higher than average prime offer rate mortgage for less than $50,000,for personal property dwelling (ie mobile), and APR > 8.5 points higher than the average second mortgage, and your APR > 8.5 points higher Mortgage for less than $20,000 and the points and fees > the lesser of 8 percent of your loan or $1,000, or loan >$20,000 and the points and fees exceed 5 percent of your loan

39 PROHIBITIONS Fees for paying all or part of early Balloon payments Late fees > 4 percent of payment Most fees for getting a payoff statement Fees for loan modifications Creditors or brokers advising homeowners refinancing into high-cost mortgages not to make their payments on an existing loan

40 SUPERVISION OF PROVIDERS Conduct due diligence to verify service provider understands and is capable of complying with federal consumer financial law Request and review service provider s s policies, procedures, internal controls, and training material to ensure that the service provider conducts appropriate training and oversight of employees or agents that have consumer contact or compliance responsibilities Include contractual provisions about compliance Establish internal on-going monitoring Take action to address problems identified Service providers are defined to include settlement service providers IMPACT-vetting companies ALTA Best Practices

41 It has been said that man is a rational animal. All my life I have been searching for evidence which could support this. -Bertrand Russell

42 "Developing Solutions to Grow Your Bottom Line" Presented by Powered by Investors Title

43 Topic: CFPB and the Changing Landscape of Real Estate Closings What you need to know about CFPB changes Proposed Tolerances Tolerance Existing RESPA Rules Proposed Integration Rules 0 Tolerance May not exceed fees estimated on the GFE Origination Charges Points Transfer Tax Fees paid to the creditorpoints, yield spread premium, processing & underwriting fee Transfer Tax Fees paid to broker Fees paid to an affiliate Fees paid to unaffiliated third party if consumer is not allowed to shop 10% Tolerance Individual fees may increase or decrease, but the sum of the charges at settlement may not be greater than ten percent above the sum of the amounts included on the GFE. Required services selected by lender Title Services and lenders title insurance if selected by lender or off list Owner s title if on list Required services selected by consumer off list Government Recording Charges Fees paid to unaffiliated third party settlement agent if consumer can shop, does not choose one, or chooses one off list provided Recording Fees No Tolerance Fees not subject to any tolerance restriction, can change at settlement and the amount of the change is not limited. Required services selected by consumer Title services and lenders title if selected by consumer and not on list Owners title not on list Initial escrow deposit Daily interest charge Homeowners insurance Prepaid interest Property insurance Escrow Charges paid to third party selected by consumer and not identified by creditor *Provided estimates are consistent with best information available to creditor at time loan estimate is made

44 FICUS BANK 4321 Random Boulevard Somecity, ST Loan Estimate date issued 7/23/2012 Applicants John A. and Mary B. 123 Anywhere Street Anytown, ST Property 456 Somewhere Avenue Anytown, ST sale price $180,000 Save this Loan Estimate to compare with your Closing Disclosure. Loan TERM 30 years Purpose Purchase ce product Fixed Rate Loan Type x Conventional FHA VA LOAN ID # RATE LOCK NO x YES, until 9/21/12 at 5:00 p.m. EDT Before closing, your interest rate, points, and lender credits can change unless you lock the interest rate. All other estimated closing costs expire on 8/6/12 at 5:00 p.m. EDT Loan Terms Can this amount increase after closing? Loan Amount $162,000 NO Interest Rate 3.875% NO Monthly Principal & Interest See Projected Payments Below for Your Total Monthly Payment Prepayment Penalty Balloon Payment $ NO Does the loan have these features? NO NO Projected Payments Payment Calculation Years 1-7 Years 8-30 Principal & Interest $ $ Mortgage Insurance Estimated Escrow Amount Can Increase Over Time Estimated Total Monthly Payment $1,050 $968 Estimated Taxes, Insurance & Assessments Amount Can Increase Over Time $206 a month This estimate includes In escrow? x Property Taxes YES x Homeowner s Insurance YES Other: See Section G on page 2 for escrowed property costs. You must pay for other property costs separately. Cash to Close Estimated Cash to Close $16,054 Includes $8,054 in Closing Costs ( $5,672 in Loan Costs + $2,382 in Other Costs $0 in Lender Credits). See details on page 2. Visit for general information and tools. Loan Estimate page 1 of 3 Loan ID #

45 Closing Cost Details Loan Costs A. Origination Charges $1, % of Loan Amount (Points) $405 Application Fee $300 Underwriting Fee $1,097 Other Costs E. Taxes and Other Government Fees $85 Recording Fees and Other Taxes $85 Transfer Taxes $0 F. Prepaids $867 Homeowner s Insurance Premium ( 6 months) $605 Mortgage Insurance Premium ( 0 months) $0 Prepaid Interest ( $17.44 per day for %) $262 Property Taxes ( 0 months) $0 B. Services You Cannot Shop For $672 Appraisal Fee $405 Credit Report Fee $30 Flood Determination Fee $20 Flood Monitoring Fee $32 Tax Monitoring Fee $75 Tax Status Research Fee $110 G. Initial Escrow Payment at Closing $413 Homeowner s Insurance $ per month for 23mo. $202 Mortgage Insurance per month for 0 mo. Property Taxes $ per month for 2 mo. $211 H. Other $1,017 Title Owner s Title Policy (optional) $1,017 I. Total Other Costs (E + F + G + H) $2,382 C. Services You Can Shop For $3,198 Pest Inspection Fee $135 Survey Fee $65 Title Insurance Binder $700 Title Lender s Title Policy $535 Title Title Search $1,261 Title Settlement Agent Fee $502 D. Total loan costs (A + B + C) $5,672 J. Total Closing Costs $8,054 D + I $8,054 Lender Credits $0 Calculating Cash to Close Total Closing Costs (J) $8,054 Closing Costs Financed (Included in Loan Amount) $0 Down Payment/Funds from Borrower $18,000 Deposit $10,000 Funds for Borrower $0 Seller Credits $0 Adjustments and Other Credits $0 Estimated Cash to Close $16,054 Loan Estimate page 2 of 3 Loan ID #

46 Additional Information About This Loan LENDER Ficus Bank NMLS/License ID Loan officer Joe Smith NMLS ID PHONE Mortgage broker NMLS/License ID Loan officer NMLS ID PHONE Comparisons In 5 Years Annual Percentage Rate (APR) Total Interest Percentage (TIP) Use these measures to compare this loan with other loans. $56,582 Total you will have paid in principal, interest, mortgage insurance, and loan costs. $15,773 Principal you will have paid off % Your costs over the loan term expressed as a rate. This is not your interest rate % The total amount of interest that you will pay over the loan term as a percentage of your loan amount. Other Considerations Appraisal Assumption Homeowner s Insurance Late Payment Refinance Servicing We may order an appraisal to determine the property s value and charge you for this appraisal. We will promptly give you a copy of any appraisal, even if your loan does not close. You can pay for an additional appraisal for your own use at your own cost. If you sell or transfer this property to another person, we will allow, under certain conditions, this person to assume this loan on the original terms. x will not allow this person to assume this loan on the original terms. This loan requires homeowner s insurance on the property, which you may obtain from a company of your choice that we find acceptable. If your payment is more than 15 days late, we will charge a late fee of 5% of the monthly principal and interest payment. Refinancing this loan will depend on your future financial situation, the property value, and market conditions. You may not be able to refinance this loan. We intend to service your loan. If so, you will make your payments to us. x to transfer servicing of your loan. Confirm Receipt By signing, you are only confirming that you have received this form. You do not have to accept this loan because you have signed or received this form. Applicant Signature Date Co-Applicant Signature Date Loan Estimate page 3 of 3 Loan ID #

47 Closing Disclosure This form is a statement of final loan terms and closing costs. Compare this document with your Loan Estimate. Closing Information Date Issued 9/10/2012 Closing Date 9/14/2012 Disbursement Date 9/14/2012 Agent Epsilon Title Co. File # Property 456 Somewhere Ave Anytown, ST Sale Price $180,000 Transaction Information Borrower John A. and Mary B. 123 Anywhere Street Anytown, ST Seller Steve C. and Amy D. 321 Somewhere Drive Anytown, ST Lender Ficus Bank Loan Information Loan Term Purpose Product 30 years Purchase Fixed Rate Loan Type x Conventional FHA VA Loan ID # MIC # Loan Terms Can this amount increase after closing? Loan Amount $162,000 NO Interest Rate 3.875% NO Monthly Principal & Interest See Projected Payments Below for Your Total Monthly Payment Prepayment Penalty Balloon Payment $ NO Does the loan have these features? NO NO Projected Payments Payment Calculation Years 1-7 Years 8-30 Principal & Interest Mortgage Insurance Estimated Escrow Amount Can Increase Over Time $ $ Estimated Total Monthly Payment $1, $ Estimated Taxes, Insurance & Assessments Amount Can Increase Over Time See Details on Page 4 $ a month This estimate includes x Property Taxes x Homeowner s Insurance x Other: Homeowner s Association In escrow? YES YES NO See page 4 for escrowed property costs. You must pay for other property costs separately. Cash to Close Cash to Close $14, Includes $9, in Closing Costs ($4, in Loan Costs + $5, in Other Costs $0 in Lender Credits). See details on page 2. CLOSING DISCLOSURE PAGE 1 OF 5 LOAN ID #

48 Closing Cost Details Loan Costs Borrower-Paid Seller-Paid Paid by Others At Closing Before Closing At Closing Before Closing A. Origination Charges $1, % of Loan Amount (Points) $ Application Fee $ Underwriting Fee $1, B. Services Borrower Did Not Shop For $ Appraisal Fee to John Smith Appraisers Inc. $ Credit Report Fee to Information Inc. $ Flood Determination Fee to Info Co. $ Flood Monitoring Fee to Info Co. $ Tax Monitoring Fee to Info Co. $ Tax Status Research Fee to Info Co. $ C. Services Borrower Did Shop For $2, Pest Inspection Fee to Pests Co. $ Survey Fee to Surveys Co. $ Title Insurance Binder to Epsilon Title Co. $ Title Lender s Title Insurance to Epsilon Title Co. $ Title Title Search to Epsilon Title Co. $ Title Settlement Agent Fee to Epsilon Title Co. $ D. TOTAL LOAN COSTS (Borrower-Paid) $4, Loan Costs Subtotals (A + B + C) $4, $29.80 Other Costs E. Taxes and Other Government Fees $ Recording Fees Deed: $40.00 Mortgage: $45.00 $ State Transfer Tax $ F. Prepaids $2, Homeowner s Insurance Premium ( 12 mo.) to Insurance Co. $1, Mortgage Insurance Premium ( mo.) 03 Prepaid Interest $17.44 per day from 9/14/12 to 10/1/12 $ Property Taxes ( 6 mo.) to Any County USA $ G. Initial Escrow Payment at Closing $ Homeowner s Insurance $ per month for 2 mo. $ Mortgage Insurance per month for mo. 03 Property Taxes $ per month for 2 mo. $ Aggregate Adjustment 0.01 H. Other Costs $2, Real Estate Commission to Alpha Real Estate Broker $ Real Estate Commission to Omega Real Estate Broker $ Title Owner s Title Insurance to Epsilon Title Co. $1, HOA Capital Contribution to HOA Acre Inc. $ HOA Dues Oct to HOA Acre Inc. $ Home Inspection Fee to Engineers Inc. $ $ Home Warranty Fee to XYZ Warranty Inc. $ I. TOTAL OTHER COSTS (Borrower-Paid) $5, Other Costs Subtotal (E + F + G + H) $5, J. TOTAL CLOSING COSTS (Borrower-Paid) $9, Closing Costs Subtotals (D + I) $9, $29.80 $2, $ $ Lender Credits CLOSING DISCLOSURE PAGE 2 OF 5 LOAN ID #

49 Calculating Cash to Close Estimate Final Did this change? Total Closing Costs (J) $8, $9, YES See Total Loan Costs (D) and Total Other Costs (I) Closing Costs Paid Before Closing $0 $29.80 YES You paid these Closing Costs before closing Closing Costs Financed (Included in Loan Amount) $0 $0 NO Down Payment/Funds from Borrower $18, $18, NO Deposit $10, $10, NO Funds for Borrower Seller Credits $0 $2, YES See Seller Credits in Section L Adjustments and Other Credits $0 $ YES See details in Sections K and L Cash to Close $16, $14, Use this table to see what has changed from your Loan Estimate. NO Summaries of Transactions BORROWER S TRANSACTION Use this table to see a summary of your transaction. SELLER S TRANSACTION K. Due from Borrower at Closing $189, Sale Price of Property $180, Sale Price of Any Personal Property Included in Sale 03 Closing Costs Paid at Closing (J) $9, Adjustments Adjustments for Items Paid by Seller in Advance 08 City/Town Taxes to 09 County Taxes to 10 Assessments to 11 HOA Dues 9/14/12 to 9/30/12 $ L. Paid Already by or on Behalf of Borrower at Closing $175, Deposit $10, Borrower s Loan Amount $162, Existing Loan(s) Assumed or Taken Subject to Seller Credit $2, Other Credits 06 Rebate from Epsilon Title Co. $ Adjustments Adjustments for Items Unpaid by Seller 12 City/Town Taxes 7/1/12 to 9/14/12 $ County Taxes to 14 Assessments to CALCULATION Total Due from Borrower at Closing (K) $189, Total Paid Already by or on Behalf of Borrower at Closing (L) $175, Cash to Close x From To Borrower $14, M. Due to Seller at Closing $180, Sale Price of Property $180, Sale Price of Any Personal Property Included in Sale Adjustments for Items Paid by Seller in Advance 09 City/Town Taxes to 10 County Taxes to 11 Assessments to 12 HOA Dues 9/14/12 to 9/30/12 $ N. Due from Seller at Closing $115, Excess Deposit $10, Closing Costs Paid at Closing (J) $2, Existing Loan(s) Assumed or Taken Subject to 04 Payoff of First Mortgage Loan $100, Payoff of Second Mortgage Loan Seller Credit $2, Adjustments for Items Unpaid by Seller 14 City/Town Taxes 7/1/12 to 9/14/12 $ County Taxes to 16 Assessments to CALCULATION Total Due to Seller at Closing (M) $180, Total Due from Seller at Closing (N) $115, Cash From x To Seller $64, CLOSING DISCLOSURE PAGE 3 OF 5 LOAN ID #

50 Additional Information About This Loan Loan Disclosures Assumption If you sell or transfer this property to another person, your lender will allow, under certain conditions, this person to assume this loan on the original terms. x will not allow assumption of this loan. Demand Feature Your loan has a demand feature, which permits your lender to require early repayment of the loan. You should review your note for details. x does not have a demand feature. Late Payment If your payment is more than 15 days late, your lender will charge a late fee of 5% of the monthly principal and interest payment. Negative Amortization (Increase in Loan Amount) Under your loan terms, you are scheduled to make monthly payments that do not pay all of the interest due that month. As a result, your loan amount will increase (negatively amortize), and your loan amount will likely become larger than your original loan amount. Increases in your loan amount lower the equity you have in this property. may have monthly payments that do not pay all of the interest due that month. If you do, your loan amount will increase (negatively amortize), and, as a result, your loan amount may become larger than your original loan amount. Increases in your loan amount lower the equity you have in this property. x do not have a negative amortization feature. Escrow Account For now, your loan x will have an escrow account (also called an impound or trust account) to pay the property costs listed below. Without an escrow account, you would pay them directly, possibly in one or two large payments a year. Your lender may be liable for penalties and interest for failing to make a payment. Escrow Escrowed Property Costs over Year 1 Non-Escrowed Property Costs over Year 1 $2, Estimated total amount over year 1 for your escrowed property costs: Homeowner s Insurance Property Taxes $1, Estimated total amount over year 1 for your non-escrowed property costs: Homeowner s Association Dues You may have other property costs. Initial Payment $ A cushion for the escrow account you pay at closing. See Section G on page 2. Monthly Payment $ The amount included in your total monthly payment. will not have an escrow account because you declined it your lender does not require or offer one. You must directly pay your property costs, such as taxes and homeowner s insurance. Contact your lender to ask if your loan can have an escrow account. Partial Payment Your lender will accept payments that are less than the full amount due (partial payments). Partial payments will be applied: No Escrow Estimated Property Costs over Year 1 Escrow Waiver Fee Estimated total amount over year 1. You must pay these costs directly, possibly in one or two large payments a year. x not accept partial payments. If this loan is sold, your new lender may have a different policy. Security Interest You are granting a security interest in 456 Somewhere Ave., Anytown, ST You may lose this property if you do not make your payments or satisfy other obligations for this loan. In the future, Your property costs may change and, as a result, your escrow payment may change. You may be able to cancel your escrow account, but if you do, you must pay your property costs directly. If you fail to pay your property taxes, your state or local government may (1) impose fines and penalties or (2) place a tax lien on this property. If you fail to pay any of your property costs, your lender may (1) add the amounts to your loan balance, (2) add an escrow account to your loan, or (3) require you to pay for property insurance that the lender buys on your behalf, which likely would cost more and provide fewer benefits than what you could buy on your own. CLOSING DISCLOSURE PAGE 4 OF 5 LOAN ID #

51 Loan Calculations Total of Payments. Total you will have paid after you make all payments of principal, interest, mortgage insurance, and loan costs, as scheduled. $292, Finance Charge. The dollar amount the loan will cost you. $123, Amount Financed. The loan amount available after paying your upfront finance charge. $156, Annual Percentage Rate (APR). Your costs over the loan term expressed as a rate. This is not your interest rate % Total Interest Percentage (TIP). The total amount of interest that you will pay over the loan term as a percentage of your loan amount % Approximate Cost of Funds (ACF). The approximate cost of the funds used to make this loan. This is not a direct cost to you. 1.63% Other Disclosures Appraisal If the property was appraised for your loan, your lender is required to give you a copy at no additional cost at least 3 days before closing. If you have not yet received it, please contact your lender at the information listed below. Contract Details See your note and security instrument for information about what happens if you fail to make your payments, what is a default on the loan, situations in which your lender can require early repayment of the loan, and the rules for making payments before they are due. Liability after Foreclosure If your lender forecloses on this property and the foreclosure does not cover the amount of unpaid balance on this loan, x state law may protect you from liability for the unpaid balance. If you refinance or take on any additional debt on this property, you may lose this protection and be liable for debt remaining after the foreclosure. You may want to consult a lawyer for more information. state law does not protect you from liability for the unpaid balance.? at Questions? If you have questions about the loan terms and costs on this form, contact your lender. To get more information or make a complaint, contact the Consumer Financial Protection Bureau Refinance Refinancing this loan will depend on your future financial situation, the property value, and market conditions. You may not be able to refinance this loan. Tax Deductions If you borrow more than this property is worth, the interest on the loan amount above this property s fair market value is not deductible from your federal income taxes. You should consult a tax advisor for more information. Contact Information Lender Mortgage Broker Real Estate Broker (B) Real Estate Broker (S) Settlement Agent Name Ficus Bank FRIENDLY MORTGAGE BROKER INC. Address NMLS/ License ID 4321 Random Blvd. Somecity, ST Terrapin Dr. Somecity, MD Omega Real Estate Broker Inc. 789 Local Lane Sometown, ST Alpha Real Estate Broker Co. 987 Suburb Ct. Someplace, ST Z Z61456 Z61616 Epsilon Title Co. Contact Joe S. JIM TAYLOR Samuel G. Joseph C. Sarah A. Contact NMLS/ License ID P16415 P51461 PT1234 joesmith@ ficusbank.com JTAYLOR@ FRNDLYMTGBRKR.COM 123 Commerce Pl. Somecity, ST sam@omegare.biz joe@alphare.biz sarah@ epsilontitle.com Phone Confirm Receipt By signing, you are only confirming that you have received this form. You do not have to accept this loan because you have signed or received this form. Applicant Signature Date Co-Applicant Signature Date CLOSING DISCLOSURE PAGE 5 OF 5 LOAN ID #