The following configuration changes will be made:
Missouri
We have been providing the “MO Borrower Information Disclosure” (Cx3323), pursuant to the provisions of Mo. Code Regs. Ann. tit. 20, §§ 1140-30.090. This regulation was rescinded in 2010, in order to ensure that Missouri law and regulations complied with the S.A.F.E. Mortgage Licensing Act of 2008 (122 Stat. 2654, tit. 5 [2008]). However, we have continued to provide this disclosure even after this rescission, because one of our legal resources had indicated that the Missouri Division of Finance was planning on implementing a substantial replacement for the previously mentioned regulation in the near future.
As part of our annual state-disclosure audit, we contacted the Division of Finance to determine whether any such plans were being made and a representative from the Division indicated that no such plans were being made. We have decided, therefore, to discontinue providing Cx3323, starting on the effective date set forth below.
Please note that we will continue to provide the “MO Loan Brokerage Disclosure Statement and Agreement” (Cx3328), which was also required under a rescinded regulation (Mo. Code Regs. Ann. tit. 20, § 1140-30.080[1] & [2] [2010]), because it is still required under Mo. Ann. Stat. § 443.867 (West 2012).
North Carolina
Similar to our Missouri disclosures, we have been providing the “NC Conflict of Interest Disclosure” (Cx3768) and the “Advanced Fee/Application Disclosure” (Cx2783) pursuant to the provisions of N.C. Admin. Code tit. 4, r. 3I.0701(b) and 3I.0702 & .0703, respectively. These regulations were repealed years ago, but we have continued to provide them because one of our legal resources indicated that the North Carolina Commissioner of Banks had informally recommended that they continue to be provided after the repeal.
Pursuant to our audit, we have contacted the Commission of Banks to follow up on our previous inquiry and a representative from the Commission has confirmed that these documents are no longer required or recommended to be given. We will, therefore, discontinue providing Cx3768 and will configure Cx2783 to not print for loans secured by property in North Carolina (it will still be provided for other states).
These changes will take effect on March 14, 2014. If you have any questions or concerns about these changes, please contact Client Support at 1.800.497.3584.
March 10, 2014
DR 129252