TILA RESPA Integrated Disclosures TRID Townhall Webinar Process
TILA – RESPA Integrated Disclosures (TRID) Townhall Webinar Process and Tolerances 03/2015 Ark-La-Tex Financial Services, LLC - For internal use only 1
P r o c e s s 03/2015 Ark-La-Tex Financial Services, LLC - For internal use only 2
Closing Disclosure – Page 2 03/2015 Ark-La-Tex Financial Services, LLC - For internal use only 3
Closing Disclosure – Page 3 03/2015 Ark-La-Tex Financial Services, LLC - For internal use only 4
ALTA Closing Disclosure Calendar 03/2015 Ark-La-Tex Financial Services, LLC - For internal use only 5
Good Faith Estimate Tolerances (Today) 03/2015 Ark-La-Tex Financial Services, LLC - For internal use only 6
Loan Estimate Variances (August 1) These charges cannot increase at settlement: [Zero Tolerance] The total of these charges can increase up to 10% at settlement: [10% Tolerance] These charges can change at settlement: [No Tolerance Limitation] • Origination charges, including points and other fees paid to lender or broker (Section A) • Services paid to affiliate of lender to broker (all Sections) • Services borrower did not shop for, such as appraisal and credit report (Section B) • Transfer taxes (Section E. 02) • Services the borrower did shop for if both of the following apply (Section C): • Paid to unaffiliated third party • Consumer either selects provider on Settlement Service Providers List or does not select any provider • Recording fees (Section E. 01) • Prepaid interest (Section F) • Homeowners' insurance premium (Section F) • Initial escrow payment at closing (Section G) • Required services that you can shop for - if borrower selects an unaffiliated third party provider not on the Settlement Services providers List (Section C. ) • Charges paid to third party provider for service not required by creditor, such as home warranty fee, HOA fees (Section H) 03/2015 Ark-La-Tex Financial Services, LLC - For internal use only 7
Loan Estimate and Closing Disclosure 03/2015 * Unless affiliated with creditor or broker, then zero tolerance Ark-La-Tex Financial Services, LLC - For internal use only 8
Settlement Service Providers List 03/2015 Ark-La-Tex Financial Services, LLC - For internal use only 9
Settlement Service Providers List • If consumer is permitted to shop, we must provide written list of providers to the consumer • Must list at least one available settlement service provider for each service • Providers must correspond to the Loan Estimate, Section C. 03/2015 Ark-La-Tex Financial Services, LLC - For internal use only 10
Resetting the 10% tolerance • You have to cross the threshold: • 10% tolerance is not reset if changed circumstance increases aggregate total of charges by 10% or less • You may reissue Loan Estimate but it must be disregarded when testing for compliance with tolerances • Three-day requirement for reissuing Loan Estimate measured from the event that causes the aggregate increase to exceed 10% 03/2015 • Example • Initial Loan Estimate estimates $400 in the 10% bucket • Changed circumstance increases fees by $20 (5%) • Tolerance is not reset and revised Loan Estimate is not required • Another changed circumstance increases fees by $28 (7%) • Combined with earlier change of circumstance fees increased $48 (12%) • Revised Loan Estimate provided with new fees of $448 within three business days • Tolerance reset: Fees can increase by another 10% ($44) before closing Ark-La-Tex Financial Services, LLC - For internal use only 11
What to do now • Talk to your real estate agents and settlement agents • Flyers in Marketing Machine • More to come • Tools on Benchmark Portal • ALTA Closing Disclosure Calendar • TIP Explanation • Presentations 03/2015 Ark-La-Tex Financial Services, LLC - For internal use only 12
THANK YOU 03/2015 Ark-La-Tex Financial Services, LLC - For internal use only 13
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