TRID QUICK REFERENCE GUIDE

Transcription

1 TRID TRID QUICK REFERENCE GUIDE CMG Financial, All Rights Reserved. CMG Financial is a registered trade name of CMG Mortgage, Inc., NMLS #1820 in most, but not all states. CMG Mortgage, Inc. is an equal opportunity lender, licensed by the Department of Business Oversight under the California Residential Mortgage Lending Act No , Loans made or arranged pursuant to a California Finance Lenders Law license No Offer of credit is subject to credit approval. For information about our company, please visit us at To verify our complete list of state licenses, please visit For more information on State licenses, please visit Not intended to serve as a business solicitation for residents in Massachusetts. For Wholesale Brokers and Select Partner Clients only.

2 Contents TRID Effective Date... 2 TRID Definition of an Application... 2 Important Definitions... 2 TRID Creating New Loans... 3 Create New Loan with an Application Dated on or after 10/3/2015 & Requesting an LE... 4 Creating New Loan with Applications Dated Prior to 10/3/ Transferred Loan Creating TBD Registration Creating An AIO-All in One Registration Creating Quick Register to Advance Lock COC Change of Circumstance Ordering the Appraisal Using an Authorization Code Generate the Closing Disclosure - CD P a g e

3 TRID Effective Date TRID rules go into effect with applications taken or after 10/3/2015. The following loans are exempt from TRID rules: 1. Loans with application dates before 10/3/ All In One Loans 3. HELOCs 4. Reverse Mortgages 5. Mortgages secured by a mobile home or dwelling not attached to real property At CMG Financial, you will only need to concern yourself with the first two exemptions. We do not originate HELOCS, Reverse Mortgages or mortgages secured by a mobile home or dwelling not attached to real property. Applications on or after 10/3/2015, will be originated with the new TRID forms, Loan Estimate (LE) and Closing Disclosure (CD). This document is meant to walk you through the new technology. TRID Definition of an Application With the implementation of TRID the CFPB has redefined the application. The CFPB states that when you have the following six pieced of information, that is considered to be an application and the clock starts for disclosing. 1. The Consumer s Name 2. The Consumer s Income 3. The Consumer s Social Security Number to obtain a credit report (or unique identifier if the consumer does not have a social security number). 4. The Property Address 5. An Estimate of the Value of the Property 6. Loan Amount Important Definitions Wholesale/Broker definitions. For Select Partners, please refer to the TRID Select Partner Presentation. General Business Days: Monday Friday, excluding Saturday, Sunday and specific federal holidays. Specific Business Days: Monday Saturday excluding Sunday and specific federal holidays. 2 P a g e

4 TRID Creating New Loans On 10/3/2015, CMG s website will be updated to include a new feature, Create New Loan. Create New Loan is to be used as the starting point for all new loans. The Create New Loan feature may be found under the Dashboard Tab. After selecting the Create New Loan option, you will be taken to the New Loan screen. There you will answer a series of questions to determine whether or not your loan is subject to the new TRID Rules and the path that it will take during creation. 3 P a g e

5 Create New Loan with an Application Dated on or after 10/3/2015 & Requesting an LE Once you have an application, these instruction will walk you through creating a new loan and requesting an LE/disclosure package. After signing into CMG s website, from the Dashboard tab choose Create New Loan. From the New Loan screen, you will answer: 1. Yes you have an application. Enter the application date or choose the date from the calendar. For this scenario, the application date should be 10/3/2015 or after. 2. Yes you have a property address 3. Submit, you will be taken to the Create Loan and Generate Loan Estimate (LE) screen. 4 P a g e

6 From the Create Loan and Generate Loan Estimate (LE) screen, Upload a 3.2 file or manually enter the require fields to create the loan and generate the LE. After uploading the 3.2 file, please review the screen and complete the fields that are not available with the upload. The remaining fields should be intuitive. Appraisal Information Section Clarification: With your 3.2 upload or manual input of the Create Loan and Generate Loan Estimate (LE) screen, CMG is gathering the information to create an LE and obtain a title, closing and accurate appraisal fee 5 P a g e

7 quote. You will be required to answer three items in the Appraisal Information section to complete the quote. NOTE: This section does not speak to the etrac Appraisal ordering site. The information that we are gathering here is for fee quote purposes only. 1. Final or Re inspection 1004D Required - From the dropdown choose Yes or No. 2. Rush Fee From the dropdown choose Yes or No 3. Size (In Acres) You will have 4 options to choose from. After all of the information has been entered correctly, Generate LE Request will appear green at the bottom of the page. Click Generate LE Request. If the Generate LE Request field appears red, required items may have been missed. Please tab through the fields or look for the item that may also be highlighted red. Once all fields are completed correctly, the Generate LE Request field will appear in green. NOTE: Please do not use any punctuation in the fields when completing the form. 6 P a g e

8 After clicking on the Generate LE Request you will receive the following message that confirms that your creation was successful and it includes the new loan number. 7 P a g e

9 The newly created loan may be found in your pipeline under the Pipeline tab. Once the new loan has been created, the loan may be locked. Find the loan in the Registered section of your pipeline, click on the loan number. From the next screen, scroll down to the bottom and find the following action items. Note: A new loan action item has been added to the menu of items available after clicking on the loan number. Upload FNMA 3.2 may be used to upload an updated 3.2 file prior to submitting your loan to CMG. Once loan has been submitted and status changed to Underwriter Received, this feature will no 8 P a g e

10 longer be available. All additional updates must be requested by sending an updated 1003 for review by the underwriter. Creating New Loan with Applications Dated Prior to 10/3/2015 NOTE: Friday 2/12/2016 will be the last day CMG will accept Pre-TRID transactions. All Pre-TRID transactions must be submitted to the CMG Wholesale office no later than 2/12/2016. Loans with application dates prior to October 3, 2015 will not be accepted after 2/12/2016 and will require that the borrower re-apply and the loan will be subject to TRID rules. All loans with applications dated prior to 10/3/2015, must close and fund by 3/31/2016. Note: Construction loans are excluded from having to close by 3/31/2016 A New Loan may be created for loans with application dates prior to 10/3/2015 by following these steps. Sign into CMG s website, from the Dashboard tab choose Create New Loan. From the New Loan screen, you will answer: 1. Yes you have an application. Enter the application date or choose the date from the calendar. 2. Yes you do have a property address 3. Submit, you will be taken to the Create Loan ONLY (no LE will be generated) screen. 9 P a g e

11 From the Create Loan ONLY (No LE will be generated) Screen, you will need to complete the required information. A 3.2 Upload is not available on this screen. Once all of the fields have been entered, the Registration field at the bottom of the page will appear green. Click on Register to create your TBD registration. 10 P a g e

12 If the Register field appears red, required items may have been missed. Please tab through the fields or look for the item that may also be highlighted red. Once all fields are completed correctly, the Register field will appear in green. NOTE: Please do not use any punctuation in the fields when completing the form. After clicking Register you will receive the following message that confirms that your creation was successful and it includes the new loan number. The newly created loan may be found in your pipeline under the Pipeline tab. 11 P a g e

13 Once the new loan has been created, the FNMA 3.2 file may be uploaded and loan locked. Find the loan in the Registered section of your pipeline, click on the loan number. From the next screen, scroll down to the bottom and find the following action items. Note: The Broker will be responsible for disclosing all up front disclosures to the borrower(s). Transferred Loan Transferred loans: A transferred loan is a loan where CMG did not prepare the initial Loan Estimate (LE) within 3 general business days of receiving the application and the broker/borrower want CMG to be the creditor on that particular transaction. Effective on Monday, 2/1/2016, CMG will only allow transferred loans where the initial LE was prepared in the broker s name and no creditor/lender was identified on the LE. Loans where the initial LE was prepared in another lender/creditor s name are not eligible for transfer. A new loan application and applicable LE will be required (NEW) Requirements: 12 P a g e

14 Expired Loan Estimates: Transaction where an LE (non-cmg LE) was prepared in the broker s name and issued within 3 general business days of receiving the loan application. The borrower did NOT provide an Intent to Proceed (ITP) within 10 days of the LE being issued. o CMG will accept that loan with a copy of the initial expired Broker LE (It must be a minimum of 11 days from the issue date) and a LOE from the loan officer stating that the Intent to Proceed (ITP) was never provided by the borrower(s). Cancelled or Withdrawn loans: Transactions where an LE (non CMG LE) was prepared in the broker s name and issued within 3 general business days of receiving the loan application. The borrower(s) DID provide an Intent to Proceed (ITP). The transaction is later withdrawn or cancelled by the borrower. o CMG will accept that loan with a copy of the initial LE that was issued in the broker s name within 3 business days of the application date and a LOE from the borrower that they wish to cancel their application with the initial investor/lender and want to proceed with an application with CMG Financial. The LOE must be dated and the CMG Loan Estimate must be requested within 2 business days form the date on the letter. The transfer letter does not need to include the name of the original lender. A Sample Copy of this letter may be found on the TRID Resource page in the Reference Material Section Sign into CMG s website, from the Dashboard tab choose Create New Loan. From the New Loan screen, you will answer: 1. Yes you have an application. Enter the application date from the original application or choose the date from the calendar. 2. Yes you do have a property address 3. Submit 13 P a g e

15 After hitting submit you will be taken to the Need More Info screen. 1. Answer whether or not you have a compliant LE. If the answer is No, you will need to have the borrower reapply before submitted your loan to CMG. 2. Choose the status of the loan from the drop down. 3. Submit 14 P a g e

16 NOTE: When completing the Create Loan and Generate LE screen, please consider the date of the borrower s written request expressing their desire to submit their application to CMG Financial or denial letter as the application date. Please refer to page 5 and follow the steps. Creating TBD Registration A TBD registration may be created by following these steps. Sign into CMG s website, from the Dashboard tab choose Create New Loan. 15 P a g e

17 From the New Loan screen, you will answer: 4. Yes you have an application. Enter the application date or choose the date from the calendar. 5. No you do not have a property address 6. Submit, you will be taken to the Create Loan ONLY (no LE will be generated) screen. From the Create Loan ONLY (No LE will be generated) Screen, you will need to complete the required information. A 3.2 Upload is not available on this screen. 16 P a g e

18 Once all of the fields have been entered, the Registration field at the bottom of the page will appear green. Click on Register to create your TBD registration. If the Register field appears red, required items may have been missed. Please tab through the fields or look for the item that may also be highlighted red. Once all fields are completed correctly, the Register field will appear in green. NOTE: Please do not use any punctuation in the fields when completing the form. After clicking Register you will receive the following message that confirms that your creation was successful and it includes the new loan number. 17 P a g e

19 The newly created loan may be found in your pipeline under the Pipeline tab. TBD Next steps: The LE/Disclosure package will not be created or sent to the borrower. Once a property has been identified, within 2 business days you will need to notify your Account Manager and provide him/her with the property address. The Account Manager will update the account with the property address and remove the TBD from the program code. Once these updates have been made you will be able to request the LE. The Generate a Loan Estimate option can be found by locating the loan in your pipeline, clicking on the loan number and scrolling down to the Loan Action items. 18 P a g e

20 Creating An AIO-All in One Registration The AIO-All In One program is exempt from TRID Rules. An AIO loan may be created following these steps. Sign into CMG s website, from the Dashboard tab choose Create New Loan. From the New Loan screen, you will answer: 1. Yes you have an application. Enter the application date or choose the date from the calendar. 2. Yes you do have a property address. 3. Yes this is an AIO loan. 4. Submit, you will be taken to the Create Loan ONLY (no LE will be generated) screen. 19 P a g e

21 From the Create Loan ONLY (No LE will be generated) Screen, you will need to complete the required information. A 3.2 Upload is not available on this screen. Once all of the fields have been entered, the Registration field at the bottom of the page will appear green. Click on Register to create your TBD registration. 20 P a g e

22 If the Register field appears red, required items may have been missed. Please tab through the fields or look for the item that may also be highlighted red. Once all fields are completed correctly, the Register field will appear in green. NOTE: Please do not use any punctuation in the fields when completing the form. After clicking Register you will receive the following message that confirms that your creation was successful and it includes the new loan number. 21 P a g e

23 The newly created loan may be found in your pipeline under the Pipeline tab. Once the new loan has been created, the FNMA 3.2 file may be uploaded and loan locked. Find the loan in the Registered section of your pipeline, click on the loan number. From the next screen, scroll down to the bottom and find the following action items. NOTE: The AIO All In One program is TRID exempt, it is the broker s responsibility to send out the early disclosures to the borrower(s). 22 P a g e

24 Creating Quick Register to Advance Lock On those rare occasions when you do not have the six pieces of information that define an application or you have a complete application and need to quickly lock the loan, we have that covered. A Quick Register to Advance Lock registration may be created by following these steps. Sign into CMG s website, from the Dashboard tab choose Create New Loan. From the New Loan screen, you will answer: 1. No you do not have an application. 2. Yes you do have a property address 3. Yes you would like to Quick Register to Advance Lock 4. Submit - you will be taken to the Create Loan ONLY (no LE will be generated) screen 23 P a g e

25 From the Create Loan ONLY (No LE will be generated) Screen, you will need to complete the required information. A 3.2 Upload is not available on this screen. Once all of the fields have been entered, the Registration field at the bottom of the page will appear green. Click on Register to create your new loan. 24 P a g e

26 If the Register field appears red, required items may have been missed. Please tab through the fields or look for the item that may also be highlighted red. Once all fields are completed correctly, the Register field will appear in green. NOTE: Please do not use any punctuation in the fields when completing the form. After clicking Register you will receive the following message that confirms that your creation was successful and it includes the new loan number. The newly created loan may be found in your pipeline under the Pipeline tab. 25 P a g e

27 Search for the loan within the pipeline. Once found, click on the loan number. This will open the loan and appropriate action items. To lock the loan, choose the Lock action item and complete the required fields to lock the loan. Note: An LE has not been generated. The LE must be requested within two General Business Days of the loan being locked or risk the lock being cancelled. Automated reminders will be sent to the contacts provided when loan created. The LE may be requested by accessing the loan within the pipeline. Click on the loan number, scroll down to the action items and choose, Generate Loan Estimate. 26 P a g e

28 After choosing Generate Loan Estimate, the Create Loan and Generate Loan Estimate (LE) screen will open. From here you will upload your FNMA 3.2 file or manually complete the fields to create your LE. Refer to page 5 of this document and follow the steps. 27 P a g e

29 COC Change of Circumstance You can notify CMG of a COC Change of Circumstance by submitting an online request. Any fee increase or new fee incurred by the broker that will be charged to the borrower must be reported to CMG at the time that you are aware of the fee. The COC action items will be available until the loan is cleared to close. The COC option can be found by clicking on the loan number or action item to the far right of the loan number. After clicking on the loan number, the following screen will open and under the Loan Action section you will find the Broker COC Request. 28 P a g e

30 By clicking on the action item to the far right hand side of the screen, the following screen will open and you will find the Broker COC Request under the action items. After opening either action item, you will be taken to the COC screen. Please enter any new or updated fees as they incur, provide instructions and hit submit. CMG will be notified of the fee change or update and process accordingly. Please note that ALL changes to loan amounts, program/product, appraised value, sales price and appraisal inspections will be processed by CMG once the underwriter has reviewed and approved. 29 P a g e

31 Ordering the Appraisal Using an Authorization Code At the time that CMG generates the LE, we will also create the authorization code that is needed to order the appraisal via the etrac Appraisal ordering site. This code will be ed to the address or addresses provided at the time that the LE was requested. This authorization code will also be placed in the Notes tab inside of the loan for future reference. The will be sent from and the subject line will be Global DMS Code and reference your CMG loan number. See below for a sample of the that will be sent. The authorization code must be entered into the Authorization Code field inside of the etrac appraisal ordering site when placing the order. Note: The appraisal cannot not be ordered until the a primary borrower has opened/received the LE and he/she has indicated their Intent to Proceed. 30 P a g e

32 Generate the Closing Disclosure - CD Once the underwriter has placed the Approved loan in CTC status, the Closing Disclosure (CD) Order Request will be an available action items inside of the loan. From the pipeline screen, find the loan, click on the loan number. After the loan opens, scroll to the bottom, there you will find the Closing Disclosure (CD) Order Request action item. Click on the action item to open the Closing Disclosure (CD). Complete the required information within the online Closing Disclosure to schedule the loan for closing and request the Closing Disclosure (CD). Most of the information will be completed on this screen as the information is gathered during the approval process. 31 P a g e