“TRID 2.0” (82 FR 37656 ) amends Regulation Z to require the total of post-consummation draw, inspection, and handling fees to be disclosed in addenda to the Loan Estimate (“LE”) and Closing Disclosure (“CD”). For details about these amendments, please visit our analysis at: https://compliance.docutech.com/2018/04/02/post-consummation-fees-and-trid/.
To comply with these, we have created a new series of fields identified by the prefix “Post-Closing Construction Fee” (most, but not all, fields within the range FI 121081 through 121478). When any of these contain a value, it will trigger a new table, labelled “Inspection and Handling Fees Collected After Closing”, to appear in an addendum (see 12 CFR Pt. 1026, Supp. I, Paragraphs 37[f] – 3 & 38[f] – 2).
The table will be formatted similar to a section appearing in the “Loan Cost” tables on the LE and CD, in order to comply with the requirements of Ibid. Paragraphs 37(o)(5) – 5 & 38(t)(5) – 5, which require that any information disclosed on “a separate page” be formatted similar to the LE and CD (albeit on the addendum to the CD, the “Borrower-Paid” and “Seller-Paid” columns will appear without any sub-columns, since all fees disclosed are paid post consummation).
Based on informal, verbal guidance from the BCFP, an itemized list of each of these fees will appear under the heading. A total of such fees will appear at the end, after the caption “Total Inspection and Handling Fees”.
These changes will only be in effect if the TRID 2.0 Indicator (FI 118689) is set to “Yes”, starting June 30, 2018. If you have any questions or concerns about these changes, please contact Client Support at 1.800.497.3584.