This document is provided pursuant to the provisions of Cal. Fin. Code §§ 22314 & 22338 and Cal. Code Regs. tit. 10, § 1454. Subsection (a)(2) of the regulatory requirement states that this document must contain the following:
“A statement of the actual amount of cash received and retained by the borrower and a statement of any funds (not including any charges within the meaning of Section 22306) paid to third persons pursuant to the written instructions of the borrower.”
While our TRID- and HELOC-versions of this document do cross-reference other documents which provide this information (e.g. Docutech’s generic “Itemization of Fees” disclosure), the non-TRID version has traditionally relied upon the GFE for disclosing this information, which, debatably, falls short.
In order to provide a better level of compliance, we will be making the following edits to the document, which will appear when “HELOC” and “Integrated Disclosure Loan Indicator” equals “No”:
- The document will now also cross-reference the Itemization of Amount Financed; and
- It will include a “Summary of Borrower’s Transaction” table (the same as is on our generic “Loan Summary 01-01-10” document).
These changes will take effect on November 28, 2015. If you have any questions or concerns about these changes, please contact Client Support at 1.800.497.3584. D