MORTGAGE MORTGAGE DISCLOSURE DISCLOSURE IMPROVEMENT ACTIMPROVEMENT ACT

MDIAMDIA

Today’s ObjectiveToday’s Objective

LEARN THE IMPORTANCE OF THIS LEARN THE IMPORTANCE OF THIS REGULATION TO OUR INDUSTRY REGULATION TO OUR INDUSTRY AND CONSUMERSAND CONSUMERS

LEARN THE NEW DISCLOSURE LEARN THE NEW DISCLOSURE TIMING AND FEE COLLECTION TIMING AND FEE COLLECTION REQUIREMENTSREQUIREMENTS

UNDERSTAND THE LOAN IMPACTS UNDERSTAND THE LOAN IMPACTS IF THE REQUIREMENTS ARE NOT IF THE REQUIREMENTS ARE NOT METMET

WHY DID CONGRESS PASS THE NEW WHY DID CONGRESS PASS THE NEW LAWLAW

TO INSURE A LEVEL AND FAIR TO INSURE A LEVEL AND FAIR REGULATION FOR OUR INDUSTRYREGULATION FOR OUR INDUSTRY

ADDITIONAL CONTROLS TO ADDITIONAL CONTROLS TO PREVENT DECEPTIVE LENDING PREVENT DECEPTIVE LENDING PRACTICESPRACTICES

CONSISTENT LENDING PRACTICES CONSISTENT LENDING PRACTICES AMONG ALL LENDERSAMONG ALL LENDERS

PROTECT THE CONSUMERSPROTECT THE CONSUMERS ENPOWER THE CONSUMER TO BE ENPOWER THE CONSUMER TO BE

MORE INFORMED AND MORE MORE INFORMED AND MORE CONFIDENT ABOUT THE CONFIDENT ABOUT THE MORTGAGE PROCESSMORTGAGE PROCESS

WHAT LOANS ARE IMPACTED WHAT LOANS ARE IMPACTED BY THE NEW LAWBY THE NEW LAW

PURCHASE TRANSACTIONSPURCHASE TRANSACTIONS REFINANCE TRANSACTIONSREFINANCE TRANSACTIONS INVESTOR; NO LONGER JUST INVESTOR; NO LONGER JUST

PRIMARY RESIDENCEPRIMARY RESIDENCE HOME EQUITY LOANS (NOT HOME EQUITY LOANS (NOT

INCLUDING HOME EQUITY LINES INCLUDING HOME EQUITY LINES OF CREDIT)OF CREDIT)

OVERVIEW OF THE ACTOVERVIEW OF THE ACT

INITIAL DISCLOSURESINITIAL DISCLOSURES

RE-DISCLOSURERE-DISCLOSURE

COLLECTION OF FEESCOLLECTION OF FEES

3-7-3 RULE3-7-3 RULE

WHAT IS THE 3-7-3 WHAT IS THE 3-7-3 RULE?RULE?

INITIAL 3 DAYS: BORROWER MUST RECEIVE THE INITIAL INITIAL 3 DAYS: BORROWER MUST RECEIVE THE INITIAL DISCLOSURES INCLUDING THE TIL WITHIN 3 DAYS OF DISCLOSURES INCLUDING THE TIL WITHIN 3 DAYS OF THE INITIAL LOAN APPLICATION AND NO UPFRONT FEES THE INITIAL LOAN APPLICATION AND NO UPFRONT FEES CAN BE COLLECTED FROM THE BORROWER WITH THE CAN BE COLLECTED FROM THE BORROWER WITH THE EXCEPTION OF THE ACTUAL COST TO RUN THE CREDIT EXCEPTION OF THE ACTUAL COST TO RUN THE CREDIT REPORT UNTIL 3 BUSINESS DAYS AFTER WE HAVE REPORT UNTIL 3 BUSINESS DAYS AFTER WE HAVE PROOF OF RECEIPT OF THE INITIAL TIL FROM THE PROOF OF RECEIPT OF THE INITIAL TIL FROM THE BORROWERBORROWER

7 DAY WAIT: EARLIEST A BORROWER CAN SIGN FINAL 7 DAY WAIT: EARLIEST A BORROWER CAN SIGN FINAL LOAN DOCUMENTS IS 7 DAYS AFTER THE DELIVERY OF LOAN DOCUMENTS IS 7 DAYS AFTER THE DELIVERY OF THE INITIAL DISCLOSURES INCLUDING THE TILTHE INITIAL DISCLOSURES INCLUDING THE TIL

3 DAY RE-DISCLOSE: IF THE APR CHANGES BY 3 DAY RE-DISCLOSE: IF THE APR CHANGES BY +/- .125% FROM THE TIME THE INITIAL TIL IS SENT TO +/- .125% FROM THE TIME THE INITIAL TIL IS SENT TO THE TIME THE BORROWERS SIGN THE FINAL LOAN THE TIME THE BORROWERS SIGN THE FINAL LOAN DOCUMENTS THE BORROWER MUST RECEIVE A NEW TIL DOCUMENTS THE BORROWER MUST RECEIVE A NEW TIL 3 DAYS PRIOR TO SIGNING THE FINAL LOAN 3 DAYS PRIOR TO SIGNING THE FINAL LOAN DOCUMENTSDOCUMENTS

DEFINITION OF BUSINESS DEFINITION OF BUSINESS DAYSDAYS

ANY DAY OF THE WEEK ANY DAY OF THE WEEK EXCLUDING SUNDAYS AND EXCLUDING SUNDAYS AND HOLIDAYSHOLIDAYS

DELIVERY OF DISCLOSURESDELIVERY OF DISCLOSURES

FACE-TO-FACEFACE-TO-FACE

E-MAILE-MAIL

US MAILUS MAIL

HOW TO DOCUMENT RECEIPT HOW TO DOCUMENT RECEIPT FROM BORROWER AND WAIT FROM BORROWER AND WAIT

TIMETIME FACE TO FACE: BORROWER SIGNS A WRITTEN STATEMENT FACE TO FACE: BORROWER SIGNS A WRITTEN STATEMENT

THAT HE/SHE IS IN RECEIPT OF THE INITIAL TILTHAT HE/SHE IS IN RECEIPT OF THE INITIAL TIL– YOU MUST WAIT 3 DAYS FROM THE DATE THE BORROWER YOU MUST WAIT 3 DAYS FROM THE DATE THE BORROWER

ACKNOWLEDGED THAT THEY RECEIVED THE TIL BEFORE YOU ACKNOWLEDGED THAT THEY RECEIVED THE TIL BEFORE YOU CAN REQUEST ANY ADDITIONAL UPFRONT FEES FROM THE CAN REQUEST ANY ADDITIONAL UPFRONT FEES FROM THE BORROWERBORROWER

E-MAIL: SAVE COPY OF THE “READ” RECEIPT PROVING E-MAIL: SAVE COPY OF THE “READ” RECEIPT PROVING BORROWER OPENED UP THE E-MAIL OR BORROWER SENDS BORROWER OPENED UP THE E-MAIL OR BORROWER SENDS BACK A REPLY STATING THEY RECEIVED THE E-MAILED TILBACK A REPLY STATING THEY RECEIVED THE E-MAILED TIL– YOU MUST WAIT 3 DAYS FROM THE DATE YOU GOT THE “READ” YOU MUST WAIT 3 DAYS FROM THE DATE YOU GOT THE “READ”

RECEIPT OF THE REPLY E-MAIL BACK FROM THE BORROWER RECEIPT OF THE REPLY E-MAIL BACK FROM THE BORROWER BEFORE YOU CAN REQUEST ANY ADDITIONAL UPFRONT FEES BEFORE YOU CAN REQUEST ANY ADDITIONAL UPFRONT FEES FROM THE BORROWERFROM THE BORROWER

US MAIL: YOU MUST COPY THE OUTSIDE OF THE ENVELOPE US MAIL: YOU MUST COPY THE OUTSIDE OF THE ENVELOPE WITH THE METER POSTAGE DATE WHICH IS PROOF THAT WITH THE METER POSTAGE DATE WHICH IS PROOF THAT YOU MAILED THE DOCUMENTSYOU MAILED THE DOCUMENTS– YOU MUST WAIT A TOTAL OF 6 DAYS FROM THE DATE MAILED YOU MUST WAIT A TOTAL OF 6 DAYS FROM THE DATE MAILED

BEFORE YOU CAN REQUEST ADDITIONAL FEES FROM THE BEFORE YOU CAN REQUEST ADDITIONAL FEES FROM THE BORROWERBORROWER

EXAMPLES OF EXAMPLES OF TIMELINETIMELINE

EXAMPLE #1 (7 DAY WAIT)EXAMPLE #1 (7 DAY WAIT) AUGUST 3RD THE LOAN APPLICATION IS AUGUST 3RD THE LOAN APPLICATION IS

TAKEN AND THE INITIAL DISCLOSURES TAKEN AND THE INITIAL DISCLOSURES INCLUDING THE TIL IS SENT VIA FACE-INCLUDING THE TIL IS SENT VIA FACE-TO-FACE OR E-MAIL AND THE TO-FACE OR E-MAIL AND THE BORROWER HAS ACKNOWLEDGED THAT BORROWER HAS ACKNOWLEDGED THAT THEY RECEIVED THE TIL ON AUGUST THEY RECEIVED THE TIL ON AUGUST 3RD3RD

AUGUST 10AUGUST 10THTH IS THE SOONEST THE IS THE SOONEST THE BORROWER CAN SIGN FINAL LOAN BORROWER CAN SIGN FINAL LOAN DOCUMENTS AS LONG AS THE APR HAS DOCUMENTS AS LONG AS THE APR HAS NOT CHANGED +/- .125%NOT CHANGED +/- .125%

EXAMPLES OF EXAMPLES OF TIMELINETIMELINE(CON’T)(CON’T)

EXAMPLE #2 EXAMPLE #2 (COLLECTION OF FEES IF DISCLOSURES SENT VIA (COLLECTION OF FEES IF DISCLOSURES SENT VIA U.S.MAIL)U.S.MAIL)

AUGUST 3AUGUST 3RD RD THE LOAN APPLICATION IS TAKEN THE LOAN APPLICATION IS TAKEN AND THE INITIAL DISCLOSURES INCLUDING THE AND THE INITIAL DISCLOSURES INCLUDING THE TIL IS SENT VIA US MAILTIL IS SENT VIA US MAIL

AUGUST 10AUGUST 10THTH (WOULD BE THE 8(WOULD BE THE 8THTH BUT WE ARE NOT OPEN THAT DAY) BUT WE ARE NOT OPEN THAT DAY) IS THE IS THE SOONEST DAY YOU CAN REQUEST ADDITIONAL SOONEST DAY YOU CAN REQUEST ADDITIONAL UPFRONT FEES FROM THE BORROWER UPFRONT FEES FROM THE BORROWER

AUGUST 10AUGUST 10THTH IS THE FIRST DAY THE IS THE FIRST DAY THE BORROWER CAN SIGN LOAN DOCUMENTS AS BORROWER CAN SIGN LOAN DOCUMENTS AS LONG AS THE APR IS NOT CHANGED +/- .125%LONG AS THE APR IS NOT CHANGED +/- .125%

EXAMPLES OF EXAMPLES OF TIMELINETIMELINE(CON’T)(CON’T)

EXAMPLE #3 (RE-DISCLOSURE)EXAMPLE #3 (RE-DISCLOSURE) AUGUST 3RD THE LOAN APPLICATON IS TAKEN AND THE AUGUST 3RD THE LOAN APPLICATON IS TAKEN AND THE

INITIAL DISCLOSURES INCLUDING THE TIL IS SENT VIA FACE-INITIAL DISCLOSURES INCLUDING THE TIL IS SENT VIA FACE-TO-FACE OR E-MAIL AND THE BORROWER HAS TO-FACE OR E-MAIL AND THE BORROWER HAS ACKNOWLEDGED THAT THEY RECEIVED THE TIL ON THE 3RDACKNOWLEDGED THAT THEY RECEIVED THE TIL ON THE 3RD

AUGUST 6TH YOU CAN REQUEST ANY OTHER UPFRONT FEES AUGUST 6TH YOU CAN REQUEST ANY OTHER UPFRONT FEES (I.E. APPRAISAL FEE)(I.E. APPRAISAL FEE)

AUGUST 14TH THE LOAN IS LOCKED AND THE APR CHANGES AUGUST 14TH THE LOAN IS LOCKED AND THE APR CHANGES BY MORE THAN .125%BY MORE THAN .125%

AUGUST 17TH NEW TIL IS SENT TO THE BORROWER VIA E-AUGUST 17TH NEW TIL IS SENT TO THE BORROWER VIA E-MAIL OR FACE-TO-FACE AND THE BORROWER HAS MAIL OR FACE-TO-FACE AND THE BORROWER HAS ACKNOWLEDGED RECEIPT OF THE TIL BY ACCEPTABLE ACKNOWLEDGED RECEIPT OF THE TIL BY ACCEPTABLE MEANS MEANS

AUGUST 19TH IS THE SOONEST THE BORROWER CAN SIGN AUGUST 19TH IS THE SOONEST THE BORROWER CAN SIGN THEIR FINAL LOAN DOCSTHEIR FINAL LOAN DOCS

EXAMPLE OF FILE FLOW FROM INITIAL EXAMPLE OF FILE FLOW FROM INITIAL APPLICATION TO CONSUMMATION OF THE LOANAPPLICATION TO CONSUMMATION OF THE LOAN

AUGUST 3AUGUST 3RDRD MR. LOAN OFFICER TAKES A LOAN MR. LOAN OFFICER TAKES A LOAN APPLICATION VIA TELEPHONE AND TURNS THE LOAN APPLICATION VIA TELEPHONE AND TURNS THE LOAN INTO THE PROCESSORINTO THE PROCESSOR

AUGUST 3AUGUST 3RDRD THE PROCESSOR PREPARES THE THE PROCESSOR PREPARES THE DISCLOSURES INCLUDING THE TIL AND SENDS THEM TO DISCLOSURES INCLUDING THE TIL AND SENDS THEM TO THE BORROWER VIA E-MAIL.THE BORROWER VIA E-MAIL.

THE PROCESSOR PRINTS THE DISCLOSURES ALONG WITH THE PROCESSOR PRINTS THE DISCLOSURES ALONG WITH THE E-MAIL COVER LETTER AND PUTS THEM IN THE FILETHE E-MAIL COVER LETTER AND PUTS THEM IN THE FILE

AUGUST 4AUGUST 4THTH THE PROCESSOR RECEIVES AN E-MAIL FROM THE PROCESSOR RECEIVES AN E-MAIL FROM THE BORROWER STATING HE/SHE HAS RECEIVED THE E-THE BORROWER STATING HE/SHE HAS RECEIVED THE E-MAIL WITH THE TIL ENCLOSEDMAIL WITH THE TIL ENCLOSED

AUGUST 4AUGUST 4THTH THE PROCESSOR PRINTS THE E-MAIL THE PROCESSOR PRINTS THE E-MAIL RECEIVED FROM THE BORROWER PUTS IT IN THE FILE ON RECEIVED FROM THE BORROWER PUTS IT IN THE FILE ON TOP OF THE COPIES OF THE DISCLOSURES (THIS RECEIPT TOP OF THE COPIES OF THE DISCLOSURES (THIS RECEIPT MUST STAY IN THE FILE AND WILL BE SCANNED WITH MUST STAY IN THE FILE AND WILL BE SCANNED WITH THE CLOSED LOAN)THE CLOSED LOAN)

EXAMPLE OF FILE FLOW FROM INITIAL EXAMPLE OF FILE FLOW FROM INITIAL APPLICATION TO CONSUMMATION OF THE APPLICATION TO CONSUMMATION OF THE

LOAN (CON’T)LOAN (CON’T)

AUGUST 6AUGUST 6THTH MR. LOAN OFFICER REQUESTS FROM THE MR. LOAN OFFICER REQUESTS FROM THE BORROWER THE FEE FOR THE APPRAISAL AND/OR BORROWER THE FEE FOR THE APPRAISAL AND/OR CAN CHARGE THE BORROWERS CREDIT CARD. CAN CHARGE THE BORROWERS CREDIT CARD.

AUGUST 24AUGUST 24THTH MR. LOAN OFFICER LOCKS THE LOAN MR. LOAN OFFICER LOCKS THE LOAN AND THE APR HAS CHANGED MORE THAN .125%AND THE APR HAS CHANGED MORE THAN .125%

AUGUST 25AUGUST 25THTH THE PROCESSOR PREPARES AND SEND THE PROCESSOR PREPARES AND SEND TO THE BORROWER VIA E-MAIL OR FACE-TO-FACE THE TO THE BORROWER VIA E-MAIL OR FACE-TO-FACE THE NEW TIL. THE PROCESSOR PRINTS AND KEEPS THE NEW TIL. THE PROCESSOR PRINTS AND KEEPS THE NEW TIL IN THE LOAN FILE ALONG WITH THE ORIGINAL NEW TIL IN THE LOAN FILE ALONG WITH THE ORIGINAL TILTIL

AUGUST 26AUGUST 26THTH BORROWER ACKNOWLEDGES RECEIPT BORROWER ACKNOWLEDGES RECEIPT OF THE NEW TILOF THE NEW TIL

AUGUST 26AUGUST 26THTH THE PROCESSOR PRINTS THE THE PROCESSOR PRINTS THE ACKNOWLEDGE RECEIPT AND IT MUST STAY IN THE ACKNOWLEDGE RECEIPT AND IT MUST STAY IN THE FILE AND WILL BE SCANNED WITH THE CLOSED LOANFILE AND WILL BE SCANNED WITH THE CLOSED LOAN

EXAMPLE OF FILE FLOW FROM INITIAL EXAMPLE OF FILE FLOW FROM INITIAL APPLICATION TO CONSUMMATION OF THE LOAN APPLICATION TO CONSUMMATION OF THE LOAN

(CON’T)(CON’T)

AUGUST 28AUGUST 28THTH IS THE SOONEST THE BORROWER CAN SIGN IS THE SOONEST THE BORROWER CAN SIGN THE FINAL LOANDOCUMENTSTHE FINAL LOANDOCUMENTS

SEPTEMBER 1SEPTEMBER 1STST FUNDING DEPARTMENT RECEIVES THE FINAL FUNDING DEPARTMENT RECEIVES THE FINAL LOAN DOCS AND THE ESTIMATED HUD-1. IT IS DISCOVERED LOAN DOCS AND THE ESTIMATED HUD-1. IT IS DISCOVERED THAT THE APR HAS CHANGED MORE THAN .125% AND A THAT THE APR HAS CHANGED MORE THAN .125% AND A NEW TIL MUST BE SIGNED BYTHE BORROWERNEW TIL MUST BE SIGNED BYTHE BORROWER

SEPTEMBER 1SEPTEMBER 1STST A NEW TIL IS PREPARED AND BORROWER A NEW TIL IS PREPARED AND BORROWER RECEIVES THE NEW TIL. WRITTEN ACKNOWLEDGEMENT OF RECEIVES THE NEW TIL. WRITTEN ACKNOWLEDGEMENT OF RECEIPT OF THE TIL IS RECEIVED AND PUT IN THE FILE AND RECEIPT OF THE TIL IS RECEIVED AND PUT IN THE FILE AND WILL BE SCANNED WITH THE CLOSED LOANWILL BE SCANNED WITH THE CLOSED LOAN

SEPTEMBER 3SEPTEMBER 3RDRD IS THE SOONEST THE LOAN CAN CLOSED IS THE SOONEST THE LOAN CAN CLOSED

**IN THIS EXAMPLE WHEN THE FINAL LOAN DOCS WERE **IN THIS EXAMPLE WHEN THE FINAL LOAN DOCS WERE RETURNED AND THE APR HAS CHANGED, TO EXPEDITE THE RETURNED AND THE APR HAS CHANGED, TO EXPEDITE THE CLOSING THE FEES COULD HAVE BEEN REDUCED TO BRING CLOSING THE FEES COULD HAVE BEEN REDUCED TO BRING THE APR INTO THE ACCEPTABLE RANGE AND THE LOAN THE APR INTO THE ACCEPTABLE RANGE AND THE LOAN COULD CLOSE ON OR AFTER AUGUST 28COULD CLOSE ON OR AFTER AUGUST 28THTH (WET FUNDING (WET FUNDING STATES)**STATES)**

EXAMPLE OF FILE FLOW FROM INITIAL EXAMPLE OF FILE FLOW FROM INITIAL APPLICATION TO CONSUMMATION OF THE LOAN APPLICATION TO CONSUMMATION OF THE LOAN

(CON’T)(CON’T)

EXAMPLE #2EXAMPLE #2

MR. LOAN OFFICER TAKES A LOAN APPLICATION FACE-MR. LOAN OFFICER TAKES A LOAN APPLICATION FACE-TO-FACE ON AUGUST 3TO-FACE ON AUGUST 3RDRD

MR. LOAN OFFICER TURNS THE LOAN INTO THE MR. LOAN OFFICER TURNS THE LOAN INTO THE PROCESSOR ON AUGUST 3PROCESSOR ON AUGUST 3RDRD AND HAS PAID UPFRONT AND HAS PAID UPFRONT FOR ALL THE BORROWERS REQUIRED FEESFOR ALL THE BORROWERS REQUIRED FEES

THE PROCESSOR PREPARES THE INITIAL THE PROCESSOR PREPARES THE INITIAL DISCLOSURING INCLUDING THE TIL AND THE DISCLOSURING INCLUDING THE TIL AND THE BORROWER COMES IN TO PICK UP THE INITIAL BORROWER COMES IN TO PICK UP THE INITIAL DISCLOSURES. THE BORROWER SIGNS AND DATES A DISCLOSURES. THE BORROWER SIGNS AND DATES A STATEMENT THAT SAYS THEY RECEIVED THE TIL ON STATEMENT THAT SAYS THEY RECEIVED THE TIL ON AUGUST 3AUGUST 3RD.RD.

IN THIS CASE THE LOAN CONSUMMATION CAN TAKE IN THIS CASE THE LOAN CONSUMMATION CAN TAKE PLACE AS EARLY AS AUGUST 10PLACE AS EARLY AS AUGUST 10THTH AS LONG AS THE AS LONG AS THE APR HAS NOT CHANGED BY +/- .125%APR HAS NOT CHANGED BY +/- .125%

IMPORTANT THINGS TO IMPORTANT THINGS TO REMEMBERREMEMBER

INITIAL DISCLOSURES INCLUDING THE TIL MUST BE INITIAL DISCLOSURES INCLUDING THE TIL MUST BE PRINTED AND KEPT IN THE FILE (UNSIGNED, UNTIL THE PRINTED AND KEPT IN THE FILE (UNSIGNED, UNTIL THE ORIGINAL IS RECEIVED BACK)ORIGINAL IS RECEIVED BACK)

PROOF OF RECEIPT OF INITIAL TIL MUST BE KEPT IN THE PROOF OF RECEIPT OF INITIAL TIL MUST BE KEPT IN THE FILE FOREVER. FILE FOREVER. – PROOF OF RECEIPT CAN BE EITHER ANY OF THE PROOF OF RECEIPT CAN BE EITHER ANY OF THE

FOLLOWINGFOLLOWING COPY OF THE ENVELOPE WITH THE POSTAGE COPY OF THE ENVELOPE WITH THE POSTAGE

DATE SHOWING DISCLOSURES WERE MAILEDDATE SHOWING DISCLOSURES WERE MAILED ““READ” RECEIPT PRINTED SHOWING BORROWERS READ” RECEIPT PRINTED SHOWING BORROWERS

OPENED THE E-MAIL WITH THE TIL ATTACHED OPENED THE E-MAIL WITH THE TIL ATTACHED RETURN E-MAIL FROM THE BORROWER STATING RETURN E-MAIL FROM THE BORROWER STATING

THEY RECEIVED THE ATTACHED TILTHEY RECEIVED THE ATTACHED TIL WRITTEN STATEMENT FROM THE BORROWER WRITTEN STATEMENT FROM THE BORROWER

SIGNED AND DATED STATING THEY RECEIVED SIGNED AND DATED STATING THEY RECEIVED THE TILTHE TIL

IMPORTANT THINGS IMPORTANT THINGS TO REMEMBER (CON’T)TO REMEMBER (CON’T)

NO UPFRONT FEES OTHER THAN THE COST NO UPFRONT FEES OTHER THAN THE COST OF THE ACTUAL CREDIT REPORT CAN BE OF THE ACTUAL CREDIT REPORT CAN BE COLLECTED UNTIL AFTER 3 DAYS OF RECEIPT COLLECTED UNTIL AFTER 3 DAYS OF RECEIPT OF THE INITIAL TILOF THE INITIAL TIL

LOAN CONSUMMATION CAN NOT TAKE PLACE LOAN CONSUMMATION CAN NOT TAKE PLACE UNTIL ON OR AFTER THE 7UNTIL ON OR AFTER THE 7THTH DAY FROM THE DAY FROM THE DATE THE INITIAL TIL IS DELIVERED TO THE DATE THE INITIAL TIL IS DELIVERED TO THE BORROWERBORROWER

THE BORROWER MUST BE IN RECEIPT OF THE THE BORROWER MUST BE IN RECEIPT OF THE UPDATED TIL IF THE APR CHANGES BY MORE UPDATED TIL IF THE APR CHANGES BY MORE THAN .125% AND LOAN CONSUMMATION THAN .125% AND LOAN CONSUMMATION CAN NOT TAKE PLACE UNTIL 3 DAYS AFTER CAN NOT TAKE PLACE UNTIL 3 DAYS AFTER RECEIPT OF THE NEW TILRECEIPT OF THE NEW TIL

PROCESSOR PROCESSOR RESPONSIBILITIESRESPONSIBILITIES

VERIFY ALL INITIAL DISCLOSURES ARE PRINTED VERIFY ALL INITIAL DISCLOSURES ARE PRINTED WITHIN 3 DAYS OF THE LOAN APPLICATION BEING WITHIN 3 DAYS OF THE LOAN APPLICATION BEING RECEIVED BY THE LOAN OFFICERRECEIVED BY THE LOAN OFFICER

RETAIN ALL COPIES OF THE INITIAL DISCLOSURES RETAIN ALL COPIES OF THE INITIAL DISCLOSURES IN THE FILE UNTIL THE ORIGINAL SIGNED IN THE FILE UNTIL THE ORIGINAL SIGNED DISCLOSURES ARE RECEIVED BACKDISCLOSURES ARE RECEIVED BACK

RETAIN IN THE FILE PROOF OF HOW THE INITIAL RETAIN IN THE FILE PROOF OF HOW THE INITIAL DISCLOSURES WERE SENT TO THE BORROWERDISCLOSURES WERE SENT TO THE BORROWER– FACE-TO-FACEFACE-TO-FACE– BY E-MAILBY E-MAIL– BY US MAILBY US MAIL

PROCESSOR PROCESSOR RESPONSIBILITIES RESPONSIBILITIES

(CON’T)(CON’T) RETAIN IN THE FILE PROOF BORROWER RECEIVED THE RETAIN IN THE FILE PROOF BORROWER RECEIVED THE

INITIAL DISCLOSURESINITIAL DISCLOSURES– READ RECEIPT FROM E-MAILREAD RECEIPT FROM E-MAIL– WRITTEN SIGNED ACKNOWLEDGEMENT FROM THE WRITTEN SIGNED ACKNOWLEDGEMENT FROM THE

BORROWERBORROWER– E-MAIL RESPONSE FROM THE BORROWER STATING THEY E-MAIL RESPONSE FROM THE BORROWER STATING THEY

RECEIVED THE DISCLOSURESRECEIVED THE DISCLOSURES AT THE TIME THE LOAN DOCUMENTS ARE DRAWN AT THE TIME THE LOAN DOCUMENTS ARE DRAWN

CONFIRM IF THE APR HAS CHANGED BY THE .125% CONFIRM IF THE APR HAS CHANGED BY THE .125% TOLERANCETOLERANCE

IF THE APR HAS CHANGED OUTSIDE THE TOLERANCE IF THE APR HAS CHANGED OUTSIDE THE TOLERANCE PREPARE AND RESEND UPDATED TILPREPARE AND RESEND UPDATED TIL

KEEP IN THE FILE ALL RE-DISCLOSURES OF THE TIL THAT KEEP IN THE FILE ALL RE-DISCLOSURES OF THE TIL THAT ARE SENT TO THE BORROWERARE SENT TO THE BORROWER

KEEP IN THE FILE ALL DOCUMENTATION OF HOW THE KEEP IN THE FILE ALL DOCUMENTATION OF HOW THE REDISCLOSED TIL WAS SENT AND RECEIVED BY THE REDISCLOSED TIL WAS SENT AND RECEIVED BY THE BORROWERBORROWER

UNDERWRITERS UNDERWRITERS RESPONSIBILITY RESPONSIBILITY

VERIFY THE INITIAL TIL WAS SENT TO THE VERIFY THE INITIAL TIL WAS SENT TO THE BORROWER WITHIN 3 DAYS OF THE INITIAL BORROWER WITHIN 3 DAYS OF THE INITIAL 1003 (this is verified based off the L/O 1003 (this is verified based off the L/O signature and date on the 1003 and this signature and date on the 1003 and this should also match the Loan Originated Date should also match the Loan Originated Date in PC Lender)in PC Lender)

VERIFY THE FILE HAS THE ORIGINAL SIGNED VERIFY THE FILE HAS THE ORIGINAL SIGNED DISCLOSURES IN THE FILEDISCLOSURES IN THE FILE

VERIFY THE PROCESSOR RETAINED THE VERIFY THE PROCESSOR RETAINED THE PROOF THE BORROWERS RECEIVED THE PROOF THE BORROWERS RECEIVED THE DISCLOSURES. (I.E., READ RECEIPT, WRITTEN DISCLOSURES. (I.E., READ RECEIPT, WRITTEN ACKNOWLEDGEMENT, RETURN E-MAIL)ACKNOWLEDGEMENT, RETURN E-MAIL)

DOC DRAWER DOC DRAWER RESPONSIBILITY RESPONSIBILITY

VERIFY THAT THE APR HAS NOT CHANGED BY VERIFY THAT THE APR HAS NOT CHANGED BY MORE THAN .125% FROM THE INITIAL TILMORE THAN .125% FROM THE INITIAL TIL

IF THE APR HAS CHANGED BY MORE IF THE APR HAS CHANGED BY MORE THAN .125% FROM THE INITIAL TIL VERIFY THAN .125% FROM THE INITIAL TIL VERIFY THE FILE HAS THE REDISCLOSED TIL AND THE FILE HAS THE REDISCLOSED TIL AND PROOF THE BORROWER RECEIVED THE TIL IN PROOF THE BORROWER RECEIVED THE TIL IN THE FILETHE FILE

CONFIRM FINAL LOAN DOCUMENTS ARE NOT CONFIRM FINAL LOAN DOCUMENTS ARE NOT DATED PRIOR TO 3 DAYS AFTER THE RECEIPT DATED PRIOR TO 3 DAYS AFTER THE RECEIPT OF THE AMENDED TIL RECEIVED BY THE OF THE AMENDED TIL RECEIVED BY THE BORROWERBORROWER

FUNDER FUNDER RESPONSIBIITY RESPONSIBIITY ONCE FINAL LOAN DOCUMENTS ARE BACK ONCE FINAL LOAN DOCUMENTS ARE BACK

CONFIRM THAT THE FINAL FIGURES HAVE CONFIRM THAT THE FINAL FIGURES HAVE NOT ADJUSTED THE APR OUTSIDE OF NOT ADJUSTED THE APR OUTSIDE OF THE .125% TOLERANCETHE .125% TOLERANCE

IF THE APR HAS CHANGED OUTSIDE THE IF THE APR HAS CHANGED OUTSIDE THE TOLERANCE THEN REDISCLOSURE OF THE TIL TOLERANCE THEN REDISCLOSURE OF THE TIL MUST BE PREPARED AND THE BORROWER MUST BE PREPARED AND THE BORROWER MUST RECEIVE THE TIL AND ANOTHER 3 DAY MUST RECEIVE THE TIL AND ANOTHER 3 DAY WAITING PERIOD STARTSWAITING PERIOD STARTS

CONFIRM NO LOAN CLOSES THAT IS OUSIDE CONFIRM NO LOAN CLOSES THAT IS OUSIDE THE APR TOLERANCE UNLESS THE THE APR TOLERANCE UNLESS THE ADDITIONAL 3 DAY WAITING PERIOD HAS ADDITIONAL 3 DAY WAITING PERIOD HAS LAPSEDLAPSED