01.19.15   •   Document Updates

Recurring Announcement Concerning State-Specific Disclosure Edits Due to TRID

Last updated: 9/17/2015

One of the many types of changes occurring due to the new TILA-RESPA Integrated Disclosure requirements (TRID) are changes to state-specific disclosures. These changes take many different shapes and forms, but most are due to the fact that dozens of these disclosures incorporate, or make cross-references to, the Good Faith Estimate, Itemization of Amount Financed, HUD-1 Settlement Statement, and Truth-in-Lending Disclosure – all of which will, come October 3rd, be only given in connection with a very small pool of loans (e.g. certain downpayment assistance loans), while the Loan Estimate and Closing Disclosure will be provided in connection with the vast majority of loans.

It is therefore necessary to modify these state-specific disclosures to refer to the Loan Estimate and Closing Disclosure, rather than to the current disclosures which will no longer be printing with the state-specific disclosures in most document packages. The purpose of this Announcement is to serve as a recurring bulletin, listing out which documents are being changed, the changes being made to them, and when such edits are completed.

January 23, 2015

Itemization of Fees (Cx19175)

Several state disclosure requirements mandate that, at the time of Initials, the borrower be given a disclosure of all compensation or fees which are charged in connection with the borrower’s loan. We have generally fulfilled this requirement by providing the Itemization of Amount Financed currently required under 12 CFR § 1026.18(c).

Come October 3rd, the Itemization of Amount Financed will no longer be provided in connection with loans subject to the new Integrated Disclosure requirements (“TRID loans”), since amendments to Ibid. § 1026.18, which exempt TRID loans from its requirements, will take effect. Therefore, it is necessary to provide or reference a different disclosure which lists all fees.

Unfortunately, the Loan Estimate is not sufficient for this purpose. According to our research and feedback from staff at the CFPB, the Loan Estimate does not disclose to consumers all fees being charged in connection with their loan. Rather, it only discloses the charges that the consumer will actually pay. Other fees paid by other parties (e.g. the seller) are not disclosed. In addition, many of these state requirements apply to loans which are not covered by TRID, such as open-end loans (e.g. HELOCs), for which the Loan Estimate would not be provided, thus making it an inadequate document for compliance in this regard.

We have, therefore, decided to create two new multi-state documents which will print in Initials and will disclose all fees. One will print for TRID loans, while the other will print for HELOCs (the Itemization of Amount Financed will continue to print for non-TRID, closed-end loans). The former is still being developed, but we are pleased to announce that our new, generic “HELOC Itemization of Fees” (Cx19175) is now available and will print under the following conditions:

  • Document Package Type = Initial Disclosure
  • Heloc = Yes

Similar to the Itemization of Amount Financed, the Itemization of Fees will list all fees being charged in connection with the loan, as well as indicate who is being paid the fee, who is paying the fee, and whether the fee is being paid outside of closing or not.

This document will be available on January 23, 2015. If you have any questions or concerns about this change, please contact Client Support at 1.800.497.3584.

January 19, 2015
DR 161998

Again, as each change is made to our state-specific disclosures, we will post the announcements here.

 

February 12, 2015

HELOC Itemization of Fees (Cx19211)

This document is a copy of Cx19175, but is configured to print in Closing packages for selected states. For the present time, this document will be configured to print in Maryland and Texas Closing packages, for the following reasons.

Md. Code Ann., Com. Law § 12-120(b) allows for a lender to require a borrower to pay for the services rendered by the lender’s attorney, but only if certain conditions are met; one of which is that “the attorney’s fee [be] separately itemized on the loan settlement sheet and identified as a fee to the lender’s attorney.”

This provision applies “to any loan, other than a commercial loan, to be secured by a mortgage or deed of trust on a borrower’s primary residence” (Ibid.) and there is no provision excluding HELOCs. Therefore, it is necessary in these situations to have a type of loan settlement sheet to itemize the attorney’s fee and the “Itemization of Fees” may be used for this purpose.

7 Tex. Admin. Code § 153.13 also prohibits a home equity loan from being closed “before one business day after the date that the owner of the homestead receives . . . a final itemized disclosure of the actual fees, points, interest, costs, and charges that will be charged at closing.” A home equity loan can include HELOCs (see Tex. Const. art. 16, § 50[a][6] & [t]), therefore it is again necessary to have an itemized disclosure of fees for HELOCs in Texas, such as the “Itemization of Fees.”

New Field 82233

Until October 3rd, practically all closed-end loan document packages will include either the GFE or the HUD-1, and the TIL. After October 3rd, nearly all of these packages will be printing the LE or the CD, though there will be some which will continue to use the current documents, since the loans they are printed for will be excluded from TRID. Taken altogether, there are, in essence, two types of closed-end loans:

  • TRID loans (most loans with an application date of October 3rd or later); and
  • Non-TRID loans (loans with an application date before October 3rd and loans exempt from TRID which are originated after this date).

In order to switch the language on our documents to reference either the current or new documents, we will be using the new field Integrated Disclosure Loan Indicator (Field 82233; which will simply be referred to as “TRID” in these announcements) as a trigger to print the appropriate language. When this field equals “Yes,” the loan is considered a TRID loan; when it equals “No,” it is considered a non-TRID loan.

State-specific Disclosures

The following state-specific disclosures are being modified in the following ways – most of which essentially consist of updating references to the GFE/HUD-1/TIL on these disclosures to either the LE or CD for TRID loans, or the Itemization of Fees for HELOCs (references to the GFE/HUD-1/TIL will continue to print for non-TRID loans):

  • AK Escrow Account Agreement (Cx16005) – This document makes a reference to the initial amounts and payment periods applicable to the borrower’s escrow account, as “set forth in the 1000 line series of the Federal HUD-1 Settlement Statement.”

We are modifying this language so that it will refer to “Section G of the Federal Closing Disclosure” when “TRID = Yes” and refer to the current language when “TRID = No.”

  • AL Mortgage Broker Agreement (Cx4068) – This document makes a reference to all other fees that the borrower may be obligated to pay besides the broker’s compensation. The document states that these fees are reflected on the “Good Faith Estimate of settlement charges”.

We will be modifying this clause so that it will refer to the new “Itemization of Fees” when either “TRID” or the field called “HELOC” (Field 28859) equals “Yes.” Otherwise, this clause will refer to the “Itemization of Amount Financed.”

  • CA Advanced Fee/Application Disclosure (Cx16084) – This document informs the borrower that other fees not disclosed within the document may be payable at a later date and are shown on the “RESPA Good Faith Estimate.”

We will be referring, instead, to the “Itemization of Fees” for HELOCs (HELOC = Yes), and to the “Loan Estimate” for TRID loans (TRID = Yes). Otherwise, the document will continue to refer to the GFE.

  • CA Finance Lenders Law Statement of Loan – Brokers (Cx5188) – References to the GFE will continue to print for non-TRID loans. However, these will dynamically change to refer to the Itemization of Fees for HELOCs (HELOC = Yes) and to the Loan Estimate and Itemization of Fees for TRID loans (TRID = Yes).

In addition, the following new Clause 4 will print for HELOCs (HELOC = Yes):

“Cash Advanced: The maximum amount of your home equity line of credit is $X.XX. This is the maximum amount of cash you may receive and retain in connection with your loan.”

Due to this, we will also modify Clause 1(b) so that it no longer refers to “the actual amount of cash to be received and retained by you” when the loan is a HELOC.

  • CA Finance Lenders Law Statement of Loan – Finance Lenders (Cx14027) – The subtitle to Clause 1 (“Acknowledgment of Truth-in-Lending Disclosure”) will be changed to refer to Truth-in-Lending Disclosures, since both the TIL and the Integrated Disclosures are required by the Truth in Lending Act.

The part where the borrower acknowledges receipt of “the Federal Truth-in-Lending Disclosure Statement” will also be modified to refer to “Truth-in-Lending Act Disclosures” (which covers both disclosures provided for HELOCs and non-TRID loans), but will dynamically refer to the Closing Disclosure for TRID loans (TRID = Yes).

References to acknowledging receipt of a “Settlement Statement” in Clause 3 will be expanded to refer, in all cases, to either the Closing Disclosure or a Settlement Statement. We will also be adding a new Clause 5 to disclose the specific term of the loan.

  • CA Mortgage Brokerage Agreement (Cx2784) – Within the “Loan Services” checklist in the document is a reference to the broker providing disclosures such as the “Truth-in-Lending, Good Faith Estimate, and state disclosures.” We will be modifying this language to refer to disclosures “required under Federal, State, and other applicable requirements.”

Also, the last paragraph states that if the borrower is charged an administrative fee, then the amount of the fee will be “disclosed in Block 1 of the Good Faith Estimate.” This part will dynamically refer to “Section A of the accompanying Loan Estimate” for TRID loans (TRID = Yes) and to the “accompanying Itemization of Fees” for HELOCs (HELOC = Yes).

Finally, for clarification purposes, we will be replacing the phrase “due and payable” to “fully earned immediately” in the last sentence before the “Acknowledgment” of the document.

  • CT Agreement Concerning Nonrefundability of Advance Fees (Cx3751) – Similar to Cx16084, this document discloses that other fees not otherwise mentioned within the document may be payable later and are shown on the GFE. This disclosure will dynamically change to references instead the Itemization of Fees for HELOCs (HELOC = Yes) and Loan Estimate for TRID loans (TRID = Yes).
  • CT Nonprime Home Loan Disclosure (Cx14773) – This document contains the following text:

“These additional documents, which have been provided to you in this disclosure package, also contain information regarding the terms of your loan:

(1) Good Faith Estimate; and

(2) Truth-in-Lending Disclosure Statement.”

We will be printing the following text instead for TRID loans (TRID = Yes):

“You have also received, within this disclosure package, a Loan Estimate, which also contains additional information regarding the terms of your loan.”

  • CT Private Mortgage Insurance Disclosure (Cx1029) – The last paragraph of the body of this document states that an estimate of the initial cost of private mortgage insurance will be disclosed on the Good Faith Estimate of Settlement Charges. We will be printing a reference to the Loan Estimate for TRID loans, instead.
  • DE Broker Agreement (Cx3583) – This agreement contains several references to the GFE. We will be modifying these so that they refer to the Loan Estimate for TRID loans and to the Itemization of Fees for HELOCs.
  • IL Failure to Qualify Notice (Cx1603) – A reference is made to the fact that other loan programs for which the borrower may qualify may have costs which materially differ from the ones disclosed in the GFE. Loan Estimate will print instead of this reference for TRID loans and Itemization of Fees will print instead for HELOCs.
  • IL Private Mortgage Insurance Disclosure (Cx1311) – The text associated with the first checkbox states that “the cost of PMI will be disclosed on the Good Faith Estimate of Settlement Costs that you will receive in connection with this loan.” Due to the fact that 765 Ill. Comp. Stat. Ann. 930/15 does not require a reference to the costs of PMI and in an effort to simplify the document, we will be deleting this sentence.
  • LA Mortgage Loan Origination Agreement (Cx4828) – References to the GFE within the document will be modified so that they refer to the Loan Estimate for TRID loans and to the Itemization of Fees for HELOCs. In addition, the following last sentence in the section entitled “Duties of Applicant” will be configured to print only for closed-end loans:

“A revised [GFE or LE] will be provided to Borrower if there are material changes in the information disclosed on the original [GFE or LE].”

  • MD Application Disclosure (Cx3579) – Clause (1) states that the lender will provide the borrower with “a ‘Good Faith Estimate of Settlement Costs’”. This phrase will dynamically change to refer to “a ‘Loan Estimate’” for TRID loans and to “an ‘Itemization of Fees’” for HELOCs.
  • MD Broker Contract (Cx4565) – The last sentence in the second paragraph of this document states that the specific amounts of charges which comprise the “Loan Fee” will be disclosed to the borrower in the “Federal HUD-1 Settlement Statement required under 12 CFR § 1024.8.”

This clause will be modified to dynamically refer to the “Federal Closing Disclosure required under 12 CFR § 1026.19(f)” for TRID loans, and to the “accompanying Itemization of Fees” for HELOCs.

  • MD Closing Attorneys Fee Certification (Cx3513) – The reference to the HUD-1 Settlement Statement within the last paragraph of the body of the document will continue to print for non-TRID loans. However, this will dynamically change to refer to the Closing Disclosure for TRID loans. It will also change for HELOCs, but the reference will be to a “settlement sheet/itemization of fees,” to accommodate clients who may use a separate sheet as a “settlement sheet,” rather than the Itemization of Fees.
  • ME Broker Agreement (Cx4517) – Section 2 of this document refers the borrower to the GFE to see “a list of fees payable in connection with your application.” This reference will dynamically change to refer to the Itemization of Fees for both TRID loans and HELOCs.
  • MN Disclaimer of Loan Terms (Cx18230) – This document explains to the borrower that certain disclosures, particularly the GFE and the TIL, “are not an offer or an inducement by the lender to enter into an agreement.”

For TRID loans, this text will refer to the Loan Estimate. For HELOCs, it will refer to the “Important Terms of Our Home Equity Line of Credit” disclosure.

  • MO Loan Brokerage Disclosure Statement and Agreement (Cx3328) – This document makes several references to the Itemization of Amount Financed. This language will continue to print for non-TRID loans, but will dynamically change to refer to the “Itemization of Fees” for TRID loans and HELOCs.

Also, the first sentence of Section 7 states the following:

“We agree to provide to you a Truth-in-Lending Disclosure, transfer of servicing documents, good faith estimates of closing costs, and all other documents required by state or federal law.”

This sentence will be simplified to state the following instead:

“We agree to provide to you all documents required by state or federal law.”

  • NY Application Disclosure (Cx9710) – The reference to the GFE in the second sentence of the document will, instead, dynamically refer to the Itemization of Fees for both TRID loans and HELOCs. This reference will also be shortened from “Good Faith Estimate of Closing Costs” to “Good Faith Estimate” for non-TRID loans.
  • TX Home Equity Owner’s Affidavit Acknowledging Lender’s Compliance (Cx5010) – Sections 2 and 3 of this document will continue to print as they do now for non-TRID loans, but the following phrases will be removed for TRID loans and HELOCs, due to the fact that either the lender or a settlement agent will be providing the Closing Disclosure:

(Section 2) “or from a title insurance company”

(Section 3) “prepared by the settlement agent”

References to the HUD-1 Settlement Statement will continue to print for non-TRID loans, but will dynamically change to refer to either the Closing Disclosure (for TRID loans) or the “Itemization of Fees” (for HELOCs), as applicable.

These changes will be effective on February 19, 2015. If you have any concerns or questions about these changes, please contact Client Support at 1.800.497.3584.

February 12, 2015
Various Document Requests

 

June 8, 2015

More State–specific Disclosure Updates

  • ND Money Broker Contract (Cx1904) – Halfway through the document is a list of fees, their amounts, and a disclosure of the time when they become payable. The Description of Fees currently discloses HUD-1 fees along with corresponding HUD-1 lines. This will modified so that LE fees are disclosed without HUD-1 fee line numbers.
  • SC Mortgage Broker Fee Agreement for Financial Services (Cx3525) – This document provides references to the GFE, HUD-1, and “Shopping For Your Home Loan” booklet. These are being modified to refer to the new Integrated Disclosures and Toolkit, as applicable. In addition, the table of fees which is a copy of the Itemization of Amount Financed tables will be updated to reflect the newer tables on the Itemization of Fees disclosure.
  • MD Application Disclosure (Cx3579) – Currently, a list of seller-paid fees and their corresponding HUD-1 lines are disclosed on this document. We will be modifying this to remove the HUD-1 line numbers.
  • DC Initial Financing Agreement (Cx3633) and DC Final Financing Agreement (Cx13979) – Both of these documents duplicate page 2 of the HUD-1 in disclosing the fees being charged in connection with the loan. We will be replacing this with a duplication of the tables printing on our Itemization of Fees.

These changes will be effective on June 11, 2015. If you have any concerns or questions about these changes, please contact Client Support at 1.800.497.3584.

June 8, 2015
DR 171029

Update: Cx3525 “SC Mortgage Broker Fee Agreement for Financial Services” has additional state edits in process due to an updated Model Fee Agreement published by the South Carolina Department of Consumer Affairs (see DR 159627). The edits outlined in this announcement will be made available when we push out the other changes. A forthcoming announcement will contain more details about the Model Form changes.

Update: These edits to Cx3525 will be made available on June 23, 2015, in conjunction with our other South Carolina Edits announced here.

 

June 16, 2015

More State-specific Disclosure Updates

  • ID Mortgage Banker Application (Cx2688) – References to “good faith estimates” and “truth in lending statements” will dynamically change to “a Loan Estimate” (for TRID loans) or “a brochure concerning HELOCs” (for HELOCs), when appropriate. Please note that this document was a copy of a model form produced by the Idaho Department of Finance. However, the Department has permanently retracted their model forms, thus this document may be amended as necessary.
  • Advanced Fee/Application Disclosure (Cx2783) – References to the GFE within the first paragraph will dynamically change to refer to the Loan Estimate (for TRID loans) or the Itemization of Fees (for HELOCs), as appropriate. The signature acknowledgment section of the Georgia-specific version of the form will also dynamically change in similar fashion.
  • KY Commitment Disclosure (Cx3826) – The reference to the Itemization of Amount Financed in Section 4 of this document will be changed to refer to the Itemization of Fees.
  • Automated Valuation Model (Cx11978) – Because the disclosure concerning receiving a copy of evaluation reports will be included in the Loan Estimate, the last sentence in Cx11978 will dynamically change to state the following for TRID loans: “Your Loan Estimate provides further details concerning this right.”
  • NV Acknowledgment of Dual Capacity (Cx13030) – This document is a duplicate of the “Borrower’s Acknowledgment and Agreement Concerning Dual Capacity as Real Estate Sales Agent and Mortgage Loan Agent” model disclosure published by the Nevada Division of Mortgage Lending. Our version of the document refers to the “Good Faith Estimate” (proper noun), while the model form refers to a “good faith estimate” (common noun), which can be used to describe both the GFE and the LE. We will be updating Cx13030 to match the model form in this regard.
  • Tangible Net Benefit Worksheet (Cx12531) – The Washington-version of this document refers to the Itemization of Amount Financed. We will be changing this to refer to the Itemization of Fees instead.
  • IL Estimate of Charges Paid by Seller (Cx13000) – Two versions of this document will print. The non-TRID version will continue to print HUD line fields, while the TRID-version will print LE/CD line fields. Both versions will continue to list all seller-paid fees, with plans to enhance the document in the near future to list only fees which are disallowed by FHA or VA.
  • NV Mortgage Broker Compensation Disclosure (Cx14279) – The following clauses appear in the second paragraph of this document: “. . . on the Good Faith Estimate of Settlement Costs and the Truth in Lending disclosures that will be disclosed after application and before closing. You should review these documents and discuss them . . .” These clauses will dynamically change to the following:
  • For TRID loans: “. . . in the Loan Estimate that will be disclosed after application and before closing. You should review this document and discuss it . . .”
  • For HELOCs: “. . . in the Itemization of Fees. You should review this document and discuss it . . .”
  • NJ Disclosure Form (Cx15059) – There will be two versions of this document: one which will print for non-TRID, closed-end loans (the format of which will be the same as what is currently printing); one which will print for TRID loans, the format of which will loosely match that of the “Closing Cost Details” tables of the LE/CD (with an appropriate disclaimer stating that these fees are being disclosed separate and apart from the LE/CD).

Multi-State Configuration Edits

In addition to our state-specific disclosures, there are many changes occurring on the national level both under TRID and in conjunction with looming FHA changes. Several of our multi-state disclosures require edits in order to refer appropriately to the LE and CD, rather than the GFE, HUD-1, and TIL. As a result, we are configuring these documents to continue to print, but only for non-TRID loans which are still subject to the older requirements. Some of these documents will be substantively replaced with a new document, which contains updated references.

To wit, the following documents will be configured to print when “Integrated Disclosure Loan Indicator” equals “No”:

  • HUD-1 Addendum (Cx8) – A new “Addendum to Closing Disclosure” (Cx19493) has been created to print for TRID loans.
  • Addendum to HUD-1 FHA (Cx899) – A new “FHA Settlement Certification” has been created to print for TRID loans.
  • Truth-in-Lending Terms and Definitions (Cx1573) – Since this document is not required under Regulation Z, we will not be providing a TRID-version of it.
  • HUD-1 Addendum – 209 Borrower Credits 01-01-10 (Cx14684) – A TRID-version of this document will not be created, since fees paid by other parties will be listed directly on the CD and an itemization of tolerance cures will be included in our new Closing Instructions, once it is completed.
  • Acknowledgment of Receipt of GFE and TIL 01-01-10 (Cx14600) – A new “Acknowledgment of Receipt of Loan Estimate” (Cx19492) has been created to print for TRID loans.
  • New Construction Disclosure 01-01-10 (Cx14602) – This document will not TRID-version equivalent, due to the fact that the disclosure in it will appear on the LE.
  • Notice of Intent to Proceed 01-10-10 (Cx14642) – A new “Notice of Intent to Proceed with Loan Application” (Cx19491) has been created to print for TRID loans.
  • Loan Summary 01-01-10 (Cx14633) – We will not be creating a TRID-version of this document, since the LE contains most of the information it already discloses (plus it is not required).
  • Origination Statement Itemizing Certain HUD-1 Settlement Statement Fees and Credits (Cx14692) – No TRID-version will be created, since all the fees itemized will already be itemized on the CD.
  • HUD-1 Addendum – 105 Additional Disbursements 01-01-10 (Cx14710) – No replacement for this document for TRID will be created, since disbursements will be disclosed on the CD (and on an addendum to the CD, if necessary).
  • Truth-in-Lending Total Payments Itemization (Cx15444) – An itemization of payments will be added to the new Closing Worksheet, once it is completed.

New Multistate Documents

As mentioned above, the following new documents are being created and will print under the following conditions:

  • Notice of Intent to Proceed with Loan Application (Cx19491)
    • Document Package Type = Initial Disclosure
    • HELOC = No
    • Integrated Disclosure Loan Indicator = Yes
    • Print Notice of Intent to Proceed with Application = Yes
  • Acknowledgment of Receipt of Loan Estimate (Cx19492)
    • Document Package Type = Initial Disclosure
    • HELOC = No
    • Integrated Disclosure Loan Indicator = Yes
    • Print Acknowledgment of GFE and TIL = Yes
  • Addendum to Closing Disclosure (Cx19493)
    • Base Type = Conventional
    • Base Type = RD
    • Base Type = VA
    • Document Package Type = Closing
    • Integrated Disclosure Loan Indicator = Yes
  • FHA Settlement Certification (Cx19494)
    • Base Type = FHA
    • Document Package Type = Closing
    • Integrated Disclosure Loan Indicator = Yes

These edits and configurations for our TRID changes will be in place on June 20, 2015. If you have any concerns or questions about these changes, please contact Client Support at 1.800.497.3584.

June 16, 2015
DR 161202, 167848, 171103, 171186, and 171346

 

July 6, 2015

Changes to FNMA Form 3185

In FNMA SEL-2015-07, FNMA announced the publication of an updated version of Form 3185 (Texas Home Equity Affidavit and Agreement First Lien), which updates Clause F, Section I to refer to “final itemized disclosure provided at closing” rather than “HUD-1 or HUD-1A Settlement Statement”, due to TRID.

We are updating our duplicate of this form (Cx3442) to match this revision. Since FNMA allows for the use of this revision before the effective date of TRID, our changes will take effect on July 11, 2015. If you have any concerns or questions about these changes, please contact Client Support at 1.800.497.3584.

July 6, 2015
DR 172952

 

July 21, 2015

Changes to IL Required Underwriting Documentation (Cx4558)

Cx4558 is provided to comply with Ill. Admin. Code tit. 38, §1050.1120, which requires that borrowers be given a list of all documents needed to underwrite the loan. One of the items on the list of underwriting documents is a “Previous real estate Settlement Statement”. This is being changed for TRID loans to refer to a “Previous real estate Settlement Statement and/or Closing Disclosure”.

This change will be in place on July 24, 2015. If you have any questions or concerns about this change, contact Client Support at 1.800.497.3584.

July 21, 2015
DR 173776

 

July 23, 2015

Delay of the Know Before You Owe Rule (TRID) Effective Date.

References to “August 1st” in this announcement have been updated to “October 3rd” to reflect the postponement of the TRID effective date.

July 23, 2015
TW 122039

 

July 30, 2015

WY Notice and Explanation of Fee Increase (Cx16634 & Cx19752)

Cx16634 is provided pursuant to Wyo. Stat. Ann. §§ 40-23-113(e)(ii) & 40-23-114(d)(ii), which sets forth the following:

“(e) A mortgage lender [or mortgage broker] shall not receive any fee that inures to the benefit of the mortgage lender [or mortgage broker], either directly or indirectly, if the fee exceeds the fee disclosed on the most recent good faith estimate unless:

(ii) The mortgage lender [or mortgage broker] has provided to the borrower, no less than three (3) business days prior to the signing of the mortgage loan closing documents, a new good faith estimate of settlement costs, a clear written explanation of the increase in the fee and the reason for charging a fee that exceeds the fee which was previously disclosed.”

Due to TRID, we will be making a copy of this document (Cx19752) to print for TRID loans. References to the GFE will be changed to the Loan Estimate and this document will print under the following conditions:

  • Document Package Type = Pre-Closing
  • Document Package Type = Redisclosure
  • Integrated Disclosure Loan Indicator = Yes
  • State Code = Wyoming

Cx16634 will continue to print for Initial Disclosure and GFE Redisclosure packages. References to the GFE within the document will now dynamically refer to “GFE” for closed-end, non-TRID loans, to “Itemization of Fees” for HELOCs, and “Loan Estimate” for closed-end, TRID loans.

These changes will take effect on August 4, 2015. If you have any questions or concerns about these changes, please contact Client Support at 1.800.497.3584.

July 30, 2015
DR 165905

 

September 17, 2015

IN Notice to Borrower (Cx14601)

This document is provided pursuant to the provisions of Ind. Code Ann. § 24-5-23.5-8 and is a duplicate of the Model Form HPU-01, published by the Homeowner Protection Unit of the Office of the Indiana Attorney General on its website (http://www.in.gov/attorneygeneral/2418.htm; listed as “Borrower Notice Form”).

The Model Form was recently updated to be more compatible with TRID (e.g. updated references to the Closing Disclosure) and we will be updating our form accordingly. Unfortunately, the Office does not provide a version of their form for loans exempt from TRID (“non-TRID loans”), even though such loans are subject to the provisions of Ibid.

To accommodate for this, we will continue to print the older text from HPU-01 (which references the HUD-1), which will dynamically appear when “Integrated Disclosure Loan Indicator” = “Yes.”

These changes will take effect on September 23, 2015. If you have any questions or concerns about these changes, please contact Client Support at 1.800.497.3584.

September 17, 2015
DR 182490