How to do business with MMC under TRID

Transcription

1 How to do business with MMC under TRID Rev. 10/27/15 Presented by J.J. Sawicki, CMP AVP of TPO/Merrimack Mortgage Co, LLC Correspondent Lending with Merrimack Mortgage Rev. 9/1/2016

2 Website - Please visit our website at to access the following: Our OpenClose system Forms Condo Project Approval List Turntimes Training Resources Recorded Training Sessions TRID Central Tax Transcript Ordering Product Information Contact Information And much more!

3 Important Contact Information If you need assistance, please contact our Inside Sales Support Team. Their contact information is as follows: Elizabeth Arseneault Marianne Nutter Scenario and general questions (non-loan specific): tposupport@merrimackmortgage.com Secondary - secondary@merrimackmortgage.com Condo Project Approvals: projectapprovals@merrimackmortgage.com Attorney approvals: tposupport@merrimackmortgage.com Appraisal support: appraisalsupport@merrimackmortgage.com Pricing help/support: secondary@merrimackmortgage.com Compliance and Risk questions: complianceandrisk@merrimackmortgage.com Servicing questions: servicing@merrimackmortgage.com

4 AUS Run Requests When requesting an AUS run (DU, LP or GUS) you must: Register the loan Upload the 1003, credit and borrower's authorization to _AUS Run Requests Then and let us know the docs are there to be picked up and run If the loan is truly a TBD, please make sure the street address is listed as TBD. If an address, mock or otherwise is in our system, that will trigger MMC to contact you so we can disclose

5 MMC Fees Administration Fee: Conventional, FHA and RD - $395 VA - $0 Fees: Flood Cert - $9.50 Credit Reports - $62.50 if pulled by MMC

6 Registration/Rate Lock All loans must be priced and registered in order to submit the file to MMC Register the loan on our site at Rates are issued between 10:00 and 10:30 each business day Rate sheets are available via and on our website in the Info Center Loans may be locked up to 6:00 pm on the current business day Overnight rate lock protection is not available Locks may be extended for 7 days at -.125, 15 days at and 30 days at Loans may be extended for a maximum for 30 days unless the original lock was for 15 days. In that case, the max available extension is 15 days Our Secondary Policy is available in the Info Center on our website All loans must be priced through our system in order to be registered

7 Submission Checklists We have developed checklists that have been included in the presentation and are available to you on our website The bottom of the checklists will remind you where to upload your file These submission checklists are: Correspondent Underwriting File Submission Checklist Pre-approval Submission Checklist

8 Submitting the Underwriting File Once the initial disclosure package has been signed the full Underwriting file may be submitted MMC will review your disclosures for compliance upon submission. If any deficiencies are noted in the review, our TPO inside sales team will contact you with the deficiency and whether or not it is curable Please upload your submission file as one document Include all LEs and Change Circumstances issued Upload the Underwriting file to Underwriting Submission File and complete the Submit Loan to Lender function The "Intent to Proceed" must be signed within 10 days of the Correspondent receiving the application information. The full Underwriting file must be received within 25 days of receiving the application information Loans submitted after 4:00 pm will be submitted the next business day

9 TBDs If your submission is truly a TBD, please make sure to enter the address as TBD in the street line Without the property address, the 6 pieces of information have not been obtained and disclosure is not required If you are providing the consumer with an Early Estimate you must include the following verbiage in 12 point font or larger and it must be shown at the top of the page: Your actual rate, payments, and costs could be higher. Get an official Loan Estimate before choosing a loan.

10 Flood, Transcripts and Verbal VOEs Merrimack Mortgage will require that all Non-Table Funded Correspondent clients obtain their own tax transcripts, flood certificates and a verbal verification of employment completed within 10 days of closing.

11 When can I order my appraisal? The Consumer may pay for the appraisal as soon as the Intent to Proceed is signed. If the Loan Officer would like to pay for the appraisal and be reimbursed by the Consumer at closing, the appraisal may be ordered at any time. No form of payment (other than the credit report) can be accepted from the consumer, regardless of whether or not the payment is processed, until the Intent to Proceed has been signed.

12 Underwriting You will receive an from OpenClose notifying you that your loan has been decisioned Log into our system and you can find your decision under the Lender Loan Response document located in the edoc Manager on the Loan Snapshot screen within your loan Any conditions marked Prior to Docs are required from you before we clear the loan to close Pay close attention to your Settlement conditions as well so there are no surprises at the closing table Contact Inside Sales Support via or phone with any questions regarding the decision and / or conditions

13 Loan Statuses If your loan is approved by the Underwriter, your loans status will change to Approved and a Lender Loan Response Document will be populated in OpenClose If your loan is suspended by the Underwriter, your loans status will change to Suspended and a Lender Loan Response Document will be populated in OpenClose. The items required to take your loan out of suspense will be marked specifically as suspense conditions If your loan is denied by the Underwriter, your loans status will change to Denied and a Lender Loan Response Document will be populated in OpenClose. The UW will also send you an or call and a denial letter will be mailed out to the borrower The documents can be found in the edoc Manager

14 Reviewing the loan decision The loan summary is followed by outstanding conditions. Please note the status of these items Be sure to double check your rate lock status, expiration dates, interest rate and program Most Prior to Doc conditions need to be met by you or the borrowers In order to meet timeline requirements, some conditions will be labeled Funding when your file is cleared to close. These must be met before the wire is disbursed and the borrower signs

15 Submitting Conditions Submit conditions by uploading them through our website to _Conditions. This makes sure that your documents are secure and because we house all of our loan documents in the edoc Manager, it allows both you and MMC to track your documents now and for any future use Do not conditions directly to MMC employees Please batch your conditions whenever possible. Submit as many conditions at one time in one PDF upload Keep current turn times in mind when setting the proper expectations (normally 48 hours for condition review) It s important to remember that when conditions are submitted, this could result in additional conditions/questions

16 Turn Times Underwriting and condition turn times are posted on our daily rate sheets. Anything uploaded after 4:00 pm is considered next business day The last conditions should be submitted in time to meet TRID guidelines. This includes all invoices, hazard binders, and rate extensions Please keep in mind when submitting loans or conditions that require outside approval or condition sign off, turn times will vary. We are at the mercy of the outside agency (example RD loans) Keep in mind that submitting everything at the last minute may result in more conditions, thereby delaying your closing

17 Loan Estimate/Closing Disclosure We have created a chart to assist you in determining fee placement for the Loan Estimate and Closing Disclosure. Please refer to the LE/CD Fee Job Aid. We request that you review this document to see if your own TRID policies line up to our interpretation. If there are discrepancies please inform us and we can review and determine if they will cause challenges in loan purchasing.

18 Change of Circumstance As a reminder, Change of Circumstance requests are accepted in the following cases: An extraordinary event beyond the control of any interested party or other unexpected event specific to the consumer or transaction; Information specific to the consumer or transaction that the creditor relied upon when providing the Loan Estimate and that was inaccurate or changed after the disclosures were provided; or New information specific to the consumer or transaction that the creditor did not rely on when providing the Loan Estimate Information the creditor knew or had in its possession at the time the initial LE was issued cannot be considered a changed circumstance, even if it was not reviewed until after the LE was issued.

19 Change of Circumstance/Wait Periods When an applicable change is made to the loan, you will need to complete a Change Circumstance. Changes include but are not limited to: Settlement Provider Change Fee change or Fee addition Loan Amount Program Change TBD Flip New information related to the borrower or property that the lender did not have at the time the previous LE or CD was issued, which results in a change to closing costs MMC will require that Change of Circumstances issued after submission are uploaded to OpenClose as they occur. This will allow us to make sure that allowable Change of Circumstances are being disclosed and redisclosures are issued in compliance with the TRID regulation. Change of Circumstances must be uploaded and identified as _Changed Circumstance only. Please be aware that if the APR increased by.125% or more on a Fixed or.25% or more on an ARM, the loan becomes subject to a 7 day wait period before it can close

20 Change of Circumstance/Wait Periods Complete underwriting submission, including all Loan Estimates and Change of Circumstances issued up to point of submission, are required. As part of the Loan Setup Process, MMC will review your LE and COC s at submission and review for deficiencies. If any deficiencies are noted in the review, our TPO inside sales team will contact you with the deficiency and whether or not it is curable If the deficiency is curable, you will provide updated documentation. We will not delay the submission of the file to Underwriting. If the deficiency is not curable, we will let you know that we cannot accept the loan and that the loan will not be eligible for purchase MMC will require that Change of Circumstances issued after submission are uploaded to OpenClose as they occur. This will allow us to make sure that allowable Change of Circumstances are being disclosed and redisclosures are issued in compliance with the TRID regulation. Change of Circumstances must be uploaded and identified as _Changed Circumstance only.

21 Who provides the LE? The Correspondent will provide the Loan Estimate

22 Business Day Definitions

23 Closing Disclosure The CD must be sent out and acknowledged at least 3 PBD days prior to closing. The Correspondent will follow up with the Consumer to make sure they have acknowledged the CD at least 3 PBD days before closing and provide evidence as noted on the Correspondent Closing Checklist. All rescindable transactions (most refinances) require any non-borrowing title holder(s) to acknowledge receipt of the CD 3 PBD prior to closing. The CD may be acknowledged in one of the follow ways: Proof CD was Mailed 7 days prior to consummation CD is signed by the borrower 3 days prior to consummation received from borrower acknowledging receipt of CD 3 days prior to consummation

24 Submitting a closed loan package A complete closed loan package and the Correspondent Closing Checklist (Exhibit C) should be overnighted to: Merrimack Mortgage Company, LLC 1045 Elm Street, Suite 601 Manchester, NH Packages should be delivered to MMC by the earlier of the rate lock expiration date or 10 days from disbursement or a late delivery fee of 3bps per day will be deducted from the final funding.

25 Purchase Review Process Purchase Reviews will be completed within 3 business days of receipt of the closed loan package MMC will require all LEs and CDs issued to the consumer and the documented corresponding Change Circumstance Requests prior to purchase of the closed loan. MMC will not purchase loans without this documentation and/or are not in compliance. During the review process, we will compare all LE and CDs provided to the Consumer to ensure valid Change of Circumstance was completed. If the loan is suspended, a suspension notice will be sent to the loan contact listed on the Correspondent Closing Checklist. The suspension will list all items needed and the deadline for receipt of those missing items There will be a 7 day grace period to get the suspension conditions in. If the loan cannot be cleared within this time frame, there will be a charge of an additional 3 bps per day after the initial 7 day grace period Once loan is cleared for purchase, please allow up to 72 hours for the wire to be sent. A purchase advice will be sent to the loan contact listed on the Correspondent Closing Checklist

26 Miscellaneous Info Keep turn times in mind when reviewing time frames. Conditions are reviewed in 48 hours so all conditions to clear the loan should be in 10 business days prior to closing Conditions received after 4:00 pm go in the next business day Flood insurance is combined with Homeowner's Insurance on the LE in Section G Make sure to follow our 2016 Lender X Appraisal Fee guide when disclosing Conventional, FHA and RD. When disclosing VA appraisal fees, refer to the Cleveland VA Appraisal Fee List Any non-borrowing title holders must consent to the CD (not required on the LE) For loans that require a Power of Attorney and meet our POA Policy, the POA must be approved at least 7 SBD prior to closing The POA cannot acknowledge receipt of the CD, but may sign the CD at closing The appraisal may be ordered upon signing of the Intent to Proceed Check our website at under TRID Central

27 Questions? us at