One of the amendments to the TILA-RESPA Integrated Disclosure Rule (TRID 2.0) allows creditors to exclude recording fees and transfer taxes when determining if the total costs payable by the consumer are less than 1 percent for home-buyer assistance loans partially exempt under Regulation Z (see 12 CFR § 1026.3[h]). “Total Fees Paid By Borrower Percent of Loan Amount” (FI 101179) has been used in the past in the global field mapping of “Integrated Disclosure Loan Indicator” (FI 82233) to determine if TRID documents were required for a particular second lien loan when “Second Lien Exempt from TRID” (FI 95221) is set to “Yes”.
The “Total Fees Paid By Borrower Percent of Loan Amount” field will continue to be used to map the “Integrated Disclosure Loan Indicator” field for non-TRID 2.0 loans. For TRID 2.0, “Total Fees Paid By Borrower Minus Taxes and Other Government Fees Percent of Loan Amount” (FI 121945) will be used instead.
Any references in the “Integrated Disclosure Loan Indicator” field mapping logic to the date “10/3/2015” have been completely removed.
Once the edits are in place, “Integrated Disclosure Loan Indicator” will be set to “Yes” by default for non-HELOC loans when “Integrated Disclosure Loan Indicator Set Method” (FI 99906) is set to “ConformX Rules” and:
- “Second Lien Exempt from TRID” (FI 95221) is not “Yes”.
-OR-
- “Second Lien Exempt from TRID” is “Yes”;
- “TRID 2.0 Indicator” (FI 118689) is set to “No”; and
- “Total Fees Paid By Borrower Percent of Loan Amount” is 1 percent or more.
-OR-
- “Second Lien Exempt from TRID” is “Yes”;
- “TRID 2.0 Indicator” is set to “Yes”; and
- “Total Fees Paid By Borrower Minus Taxes and Other Government Fees Percent of Loan Amount” is 1 percent or more.
“Integrated Disclosure Loan Indicator” will be set to “No” by default when “Integrated Disclosure Loan Indicator Set Method” is set to “ConformX Rules” and:
- “Loan Purpose” (FI 5991) is “HELOC”.
-OR-
- “Second Lien Exempt from TRID” is “Yes”;
- “TRID 2.0 Indicator” is set to “No”; and
- “Total Fees Paid By Borrower Percent of Loan Amount” is less than 1 percent.
-OR-
- “Second Lien Exempt from TRID” is “Yes”;
- “TRID 2.0 Indicator” is set to “Yes”; and
- “Total Fees Paid By Borrower Minus Taxes and Other Government Fees Percent of Loan Amount” is less than 1 percent.
Please note if the “TRID 2.0 Indicator” is empty, but “Application Date” (FI 147) is prior to 10/1/2018; or both fields are empty and “Today’s Date” (FI 15408) is prior to 10/1/2018, then the TRID 1.0 logic will be followed.
Similarly, if the “TRID 2.0 Indicator” is empty, but “Application Date” is on or after 10/1/2018, or both fields are empty and “Today’s Date” is on or after 10/1/2018, then the TRID 2.0 logic will be followed.
These field mapping changes will be in place on August 25, 2018. These changes are currently available on ConformX Stage for testing. Please note that client-specific customizations may be impacted by these generic modifications. As always, we encourage clients to test these changes. If you have any questions or concerns about these changes, please contact Client Support at 1.800.497.3584.
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