TRID 2.0 Updates: Closing Disclosure (Cx18566) and Spanish Closing Disclosure (Cx18991) Changing Prepaid Interest From 0 to 0.00.

Under TRID 1.0, if no prepaid interest existed in a transaction, then “$0” was required to be disclosed Line F.03 of the Closing Disclosure, per the following:

“If interest is not collected for a portion of a month or other period between closing and the date from which interest will be collected with the first monthly payment, then $0 must be disclosed under § 1026.38(g)(2).” (12 CFR Pt. 1026, Supp. I, Paragraph 38[g][2] – 3 as it appears in 78 FR 80353 [2013]).

Under TRID 2.0, the CFPB decided to amend this Comment by changing “$0” to “$0.00” for the following reasons:

“To remain consistent with the other disclosed dollar amounts under the closing cost details column the Bureau is requiring the disclosure of $0.00 under § 1026.38(g)(2) when prepaid interest is not collected. This requirement is also consistent with § 1026.2(b)(4) and comment 38(t)(4)-1 which requires the disclosure of dollar amounts to include cents even when the value for cents is zero, unless otherwise provided.” (82 FR 37728 [2017])

To comply with this change, we will be modifying both the generic English- and Spanish-versions of the Closing Disclosure (Cx18566 and Cx18991) to print “$0.00” instead of “$0” in BOTH the “per day” and “total” amounts for Line F.03. “$0.00” for the total will appear in the Borrower-Paid At Closing Column.

Please note that “$0.00” will only appear in the Borrower-Paid At Closing column if there is a value of zero (or no value) in the fields used for all of the columns for Line F.03 (including the “Seller-Paid” and “Paid by Others” columns). This will also only apply when “TRID 2.0 Indicator” (FI 118689) equals “Yes”.

These changes will take effect on August, 17 2018. If you have any questions or concerns about this change, please contact Client Support at 1.800.497.3584

DR 268872