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Continuing Education
TILA-RESPA Integrated Disclosure
Overview What is TRID
What are the Disclosures
Timing
Exceptions
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MC Software & TRIDs
WebApp & TRIDs
Tracking
Questions
What is TRIDTILA/RESPA Integrated Disclosure Rule
Clearer Consumer Communication
Consolidates 4 forms into 2
Applies to most closed-end credit transactions secured by real property
Establishes a new definition of “application”
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What are the Disclosures?
Loan Estimate – replaces GFE and TILA
Closing Disclosure – replaces HUD-1 and Final TILA
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Loan Estimate
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Where does the LE data come from?GFE
To Modify the data make changes in GFE and select Start Over in LE to pull in changes
Special fees will have to be entered in the LE after adding to GFE
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Closing Disclosure
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Where does the CD data come from?HUD
Modify in the HUD. Select Start Over in CD to pull in changes.
Special fees must be added to the CD manually after modifying the HUD.
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Loan Estimate Timing
Creditor is required to provide the LE within three business days of the receipt of the loan *application:
In person
By mail
By email
*To qualify as an application under CFPB rules, you must receive six pieces of information: Name, Income, SSN, Property Address, Estimate of the property value, and Mortgage Loan amount requested.
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Closing Disclosure Timing
Creditor is required to ensure the consumer receives the CD no later than three business days before consummation of the loan
In person
By mail
By email
CD must be provided separately to each consumer who has the right to rescind under TILA.
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What about EasyApp received from WebApp?
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6 Pieces of info for application: Name
Income
Social Security Number
Property Address
Loan Amount
Estimated Property Value
***EasyApp is missing Estimated Property Value***
What about EasyApp received from WebApp?
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You are not “required” to provide the LE for an EasyApp
However….you can provide it if you choose.
What about Credit Approval received from WebApp?
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6 Pieces of info for application: Name
Income
Social Security Number
Property Address
Loan Amount
Estimated Property Value
***Credit Approval contain all 6 pieces of data***
What about Credit Approval received from WebApp?
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You MUST provide a Loan Estimate on Credit Approvals received through WebApp
You can “turn off” the option for Credit Approval in Maintenance>Company Misc>WebApp Information. The option will no longer display on the WebApp menu if the option is not checked.
Regulatory Tracking
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When TRID docs are requested from Docu Prep, a Pop-Up will prompt you for the date to record in Regulatory Tracking.
Click “Yes” to log the date to the Regulatory Tracking Screen.
Click “No” if you are only Proofing the form.
Exceptions
HELOCS
Reverse Mortgages
Dwellings not attached to real property
Smaller Lenders. See CFPB website for limits:
http://www.consumerfinance.gov/
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Questions
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Contact InformationClient Services
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