Preview of new TILA-RESPA Integrated Disclosure (TRID) going live August 1st 2015

2 new forms
Loan Estimate (LE) (replaces GFE & TIL) [contains new total interest paid TIP calculation] Closing Disclosure (CD) replaces HUD-1
LE to consumer w/in 3 days of Application
LE 7 days b4 closing

IMPORTANT: CD must be received no later than 3 biz days before consumation (signs the promissory note)
**most significant change that will impact the biz
Lenders responsible for generating and providing the closing disclosure (lenders may contract w/ settlement agents to provide closing disclosure) as opposed to now where settlement agents prepare the CD’s

6 pieces of information needed to trigger a loan estimate …
Required Information to trigger a Loan Estimate:

1. Consumer’s name
2. Consumer’s income
3. Consumer’s Social Security number to obtain a credit report (or other unique identifier if the consumer has no Social Security number)
4. Property address
5. Estimate of the value of the property
6. Mortgage loan amount sought

Additional 3 biz days wait period required if:

* APR increases by more than 1/8 % from disclosed amount (no change to current rules)
* loan product changes
* prepayment penalty is added

Although the creditor may request additional pieces of information, once they have received the required six items, the creditor is now required to provide the borrower with an official Loan Estimate within three business days of receiving the sixth pieces of information.

Any other changes b4 closing will not require new 3 biz day wait period, brwr does have the right to inspect a revised CD during biz day prior to closing

TILA/RESPA Integrated Disclosures
Mandatory on apps taken after Aug 1st 2015
Reverse Mtgs, Helocs & mobile homes not covered

Loan Application date = date Broker receives 6 pieces of information and 3 day clock starts for the Loan Estimate

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