New Document: Itemization of Fees (Cx19209)
Although the new Integrated Disclosure requirements will soon obviate the need for many familiar documents, some related disclosure requirements will remain in place. As previously discussed here, one of these requirements is that several states will continue to mandate that all fees charged in connection with a loan must be disclosed to the borrower. This obligation was normally satisfied by providing the Itemization of Amount Financed currently required under 12 CFR § 1026.18(c). However, beginning October 3rd, the Itemization of Amount Financed will no longer be provided in connection with loans subject to Integrated Disclosure requirements (“TRID loans”), since amendments to Ibid. § 1026.18, which exempt TRID loans from its requirements, will be in effect. Therefore, it is necessary to provide or reference a different disclosure which lists all fees.
To this end we have created two new multistate 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 HELOC Itemization of Fees (Cx19175) is already in place, as previously announced here. The second multi-state document, our new non-HELOC generic “Itemization of Fees” (Cx19209) has been created and will print under the following conditions:
Document Package Type = Initial Disclosures
Heloc = No
New “Integrated Disclosure Loan Indicator” (field 82233) = Yes
Similar to the Itemization of Amount Financed, the new Cx19209 Itemization of Fees will list all fees being charged in connection with the loan, as well as indicate who the fee is being paid to, who is paying the fee, and whether the fee is being paid outside of closing or not.
Configuration Changes for Non-TRID Generic Documents
In connection with the implementation of the Integrated Disclosure rules going into effect on August 1, many currently required disclosures will become obsolete for TRID loans. Accordingly, we will be altering the print configuration of many disclosures to ensure that they do not print for loans subject to the new Integrated Disclosure rules. These print configurations will be modified with the inclusion of a new document trigger: “Integrated Disclosure Loan Indicator” (field 82233). This TRID Indicator will be set as follows:
- If Application Date (field 147) is October 3rd or later, the new “Integrated Disclosure Loan Indicator” will be set to “Yes”.
- If Application Date is empty, and Today’s Date (field 15408) is October 3rd or later, TRID Indicator will be set to “Yes”.
- If Loan Purpose is HELOC, TRID Indicator will be set to “No”.
- If the LOS imports “Yes” or “No” data to the TRID Indicator, the imported data will override the settings made based on the fields above.
For loans subject to the new Integrated Disclosure rules after October 3rd, the following documents will no longer print (i.e., they will only print if the TRID Indicator is set to “No”):
- Cx14221 (Good Faith Estimate 01-01-10)
- Cx14643 (Settlement Service Providers 01-01-10)
- Cx20 (Servicing Disclosure Statement)
- Cx17903 (Notice of Right to Receive Copy of Appraisal Report)
- Cx17904 (Notice of Right to Receive Copy of Appraisal Report)
- Cx1591 (Initial Truth-In-Lending Disclosure)
- Cx14380 (Initial Truth-In-Lending Disclosure)
- Cx18 (Truth-In-Lending Disclosure)
- Cx14363 (Truth-In-Lending Disclosure)
- Cx13586 (Truth-In-Lending Disclosure – 2nd Lien)
- Cx14224 (Itemization of Amount Financed 01-01-10)
- Cx14644 (Itemization of Amount Financed 01-01-10)
- Cx14222 (HUD-1 01-01-10)
- Cx14223 (HUD-1A 01-01-10)
- Cx14692 (Origination Statement Itemizing 801, 1101, and Borrower Credits)
The new Itemization of Fees (Cx19209) will be available beginning March 31, 2015. The print configuration of the documents no longer applicable to loans subject to the Integrated Disclosure rules will also be altered on March 31, 2015. If you have any questions or concerns about these changes, please contact Client Support at 1.800.497.3584.
March 23, 2015
DR 161998 and DR 166885
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