Global Mapping Updates: Loan Estimate and Closing Disclosure Signature Line Indicators (FI 85190 & 95191)

While Federal Regulation Z permits, but does not require, signature lines to appear on the Loan Estimate and Closing Disclosure forms (see 12 CFR §§ 1026.37[n] & 1026.38[s]), some State administrative laws do require signatures on one or both of these documents, either for disclosure or recordkeeping requirements.

Texas’ administrative law requires the following, which provisions are applicable to licensees under Chapters 156 (Residential Mortgage Loan Companies) or 157 (Mortgage Bankers and Residential Mortgage Loan Originators) of Texas’ Finance Code:

“For each residential mortgage loan application received the residential mortgage loan file shall contain at a minimum the following: . . .

(B) either a copy of the signed closing statement or integrated closing disclosure, documentation of the time denial, or other disposition of the application for a residential mortgage loan . . .” (7 Tex. Admin. Code § 80.204[b][1][B]; emphasis added)

“A residential mortgage loan file for each mortgage loan application received; each file shall contain at a minimum the following: . . .

(B) either a copy of the signed closing statement or integrated closing disclosure, documentation of the timely denial, or other disposition of the application for a residential mortgage loan . . .” (Ibid. § 81.204[b][1][B]; emphasis added)

To help ensure that these requirements are met, we will be globally mapping “Closing Disclosure Signature Lines Indicator” (FI 95191) to “Yes” for loans secured by property located in Texas. We will also be globally mapping “Loan Estimate Signature Lines Indicator” (FI 95190) to “Yes” for loans secured by property located in Montana, due to similar requirements found in Mont. Admin. R. 2.59.1710(1) & 2.59.1724(7).

These global mappings are available on Stage servers for testing. Clients who wish to have these mappings removed or customized (either because they are not licensed under Chapters 156 or 157, or for any other reason) are free to submit a request to their Account Manager or Client Support. Note that these global mappings will not override any custom mappings already in place.

These changes will be in effect on October 12, 2019. If you have any questions or concerns about these changes, please contact Client Support at 1.800.497.3584.

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