1) Missing Loan Originator Information at Closing Error
The CFPB has created a new subsection of Regulation Z (12 CFR § 1026.36[g]), which requires that the names and NMLS numbers of the loan originator primarily responsible for a loan and the loan originating company he works for be disclosed on different loan documents, including the note and security instrument. There is some ambiguity in the regulation as to which entities these items of information should be disclosed for; whether for the broker and his originator, for the lender and his originator, or all four entities. We have taken a conservative approach and will be disclosing the information for all four in our promissory notes and security instruments.
At a minimum one individual’s name and NMLS number, and one company’s name and NMLS number must be included on the note and security instrument. Therefore, if any of the first four content fields of the NMLS originator information section that prints on the note and security instrument are empty, the user will be stopped and will not be able to proceed. The following error message will display:
“The minimum loan originator information for the Note and Security Instrument is not filled in on this loan. The Loan Originator Name and NMLS Number and Loan Origination Company Name and NMLS Number must be populated. Please contact Client Support at 1.800.497.3584.”
This new loan origination information error will only fire in non-HELOC Closing packages if “Application Taken On or After 01/10/2014” is set to “Yes”.
2) Empty Application Date and/or Closing Date Warnings
All of the new disclosures related to the January 2014 CFPB regulations are triggered based on either the Application Date or the Closing Date. If one or both of these dates is empty, Today’s Date is used to determine whether the following related indicators are set to “Yes” or “No” (and the new disclosures are triggered or not):
• Application Taken On or After 01/10/2014
• Application Taken On or After 01/18/2014
• Closing On or After 01/10/2014
The following warnings will let the user know that this has occurred:
In Initial Disclosures or Closing, if both the Application Date and Closing Date are empty:
“The Application Date and Closing Date are empty on this loan. Today’s Date will be used to determine which versions of the disclosures print in this document package.”
In Initial Disclosures or Closing, if only the Application Date is empty:
“The Application Date is empty on this loan. Today’s Date will be used to determine which versions of the disclosures print in this document package.”
In Initial Disclosures or Closing, if only the Closing Date is empty:
“The Closing Date is empty on this loan. Today’s Date will be used to determine which versions of the disclosures print in this document package.”
In TILA Redisclosure Packages, if the Application Date is missing, and the loan is set as a Second Lien Higher-Risk HPML:
“The Application Date is empty on this loan. Today’s Date will be used to determine if the “Notice of Right to Receive Copy of Appraisal Report” should print in this document package.”
These data integrity checks will be effective in ConformX beginning January 10, 2014. If you have any questions or concerns about these new checks please contact Client Support at 1.800.497.3584.
January 2, 2014
TW 86438