confidential material continuing education tila-respa integrated disclosure

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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

support@mcsoftware.com801.621.3900

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