The Ohio Division of Financial Institutions promulgated “Mortgage Brokers & Lenders Letter 2015 – 1” on October 2, 2015, advising registrants under the Ohio Mortgage Loan Act and registrants and exempt organizations under the Ohio Mortgage Broker Act of the relationship between certain state disclosure requirements and TRID (this Letter is not currently published by any Ohio government website, but is available for viewing through the Ohio MBA’s website at: http://www.ohiomba.org/wp-content/uploads/2014/03/DFI-announcement-10-2-15.pdf).
According to this Letter, “the Ohio specific form, Notice of Escrow of Taxes, and Regular Monthly Payment, is no longer necessary for mortgage loan applications taken on or after Saturday October 3, 2015.” Our equivalents of this document are Cx11197 and Cx11205, which are provided pursuant to Ohio Rev. Code Ann. §§ 1321.592(A) & 1322.063, respectively.
Due to this Letter, we will be adding to these two documents’ print configurations the following trigger:
- Integrated Disclosure Loan Indicator = No
The Letter further stipulates that the Mortgage Loan Origination Disclosure Statement (“MLODS”) and, by implication, its addendum (our equivalents are Cx3472 and Cx11204, respectively) must still be provided, regardless of TRID.
Furthermore, a special exemption is made for the disclosure of material changes required under Ibid. § 1322.064. The Division stipulates that the disclosure required by this section “may be provide via a revised Loan Estimate, when the timelines set forth in the CFPB are met.” We provide the “Ohio Notice of Change in Mortgage Terms” (Cx12463) for this requirement, which is a duplicate of the model form published on the Ohio Department of Commerce’s website (http://www.com.ohio.gov/).
However, we will not be making any configuration changes for this document due to the fact that it is also provided pursuant to Ibid. §§ 1321.594 & 1322.062(B), which are not addressed in the Letter and thus making it dubious as to whether these sections of law will be sufficiently complied with in providing a revised LE.
Changes to Cx11197 and Cx11205 will take effect on October 14, 2015. If you have any questions or concerns about these changes, please contact Client Support at 1.800 497.3584.
October 7, 2015