Despite the fact that TRID was originally proposed in the middle of 2012 (see 77 FR 51116 ) and finalized at the end of 2013 (see 78 FR 79730 ), several states have not updated their legislation, regulations, or even forms to make them compatible with the new Integrated Disclosures.
In addition, forms provided by Federal agencies and GSEs have also not been so updated. Unfortunately, the content of these documents cannot be altered since they are prescribed by law or regulation. The consequence of such is that, unless such laws and regulations are amended before TRID takes effect, borrowers will receive disclosures referring to documents which do not appear in their loan packages.
As a temporary workaround for this, we will be printing new Cx19708 in all TRID-loan packages. This document explains, in simple terms, the fact that some documents may refer to other documents (GFE, HUD-1 or HUD-1/A, and “Settlement Costs Booklet”) which are not actually in the package, but that other documents within the package (LE, CD, and “Your home loan toolkit”) will disclose the same information.
This document will eventually be phased out as multi-state and state-specific disclosures are made compatible with TRID. Some of the documents we have identified as needing legislative and/or administrative changes to conform not only to TRID, but to the entire Dodd-Frank Act, include the following:
- 26-1820 Report and Certification of Loan Disbursement (Cx52)
- Request for a Certificate of Eligibility for VA Home Loan Benefits (Cx3957)
- Subterranean Termite Soil Treatment Builder’s Guarantee-HUD-NPMA-99A (Cx3970)
- Builders Certification – HUD-92541 (Cx3971)
- HUD FHA/VA Addendum (Cx3981)
- Origination Statement Itemizing Certain HUD-1 Settlement Statement Fees and Credits (Cx14692)
- Conditional Commitment for SFH Loan Guarantee – RD 3555-18 (Cx18892)
- CA Notice of Right to Receive Copy of Appraisal Report (Cx18023)
- CA Disclosure Receipt (Cx2687)
- CA Balloon Disclosure Regarding Extension of Credit (Cx2786)
- CA Mortgage Loan Disclosure Statement (Cx2798)
- CA Mortgage Loan Disclosure Statement/Good Faith Estimate (Cx12922)
- CO Lock-In Disclosure (Cx13134)
- Acknowledgment of Receipt of GFE and TIL 01-01-10 (Cx14600; pursuant to Georgia law)
- IL Borrower Information Document (Cx1206)
- IL Mortgage Escrow Account Act (Cx1207)
- IL Mortgage Escrow Account Act (Cx16095)
- IN Notice to Borrower (Cx14601)
- MI Borrowers Bill of Rights and Consumer Caution Notice (Cx4970)
- OH Addendum to the GFE (Cx11204)
- OR Spanish General Disclosure (Cx15657)
- OR Spanish Good Faith Estimate (Cx15656)
- OR Spanish Truth-in-Lending Disclosure (Cx15658)
- RI Tangible Net Benefit (Cx11242)
- WA Broker Application Disclosure (Cx2655)
- WI Mortgage Broker Agreement (Cx14547)
Cx19708 will be available on July 17, 2015. If you have any questions or concerns about this document, please contact Client Support at 1.800.497.3584.
July 10, 2015