September 30th, 2015 1:18 PM by Robin Bain
Lender charges and credits
Mortgage broker's charges
Paid to affiliate of creditor or broker
Unaffiliated third party if shopping not allowed
10% Aggregate Increase
Unaffiliated third party if shopping allowed but consumer does not shop
Best Information Reasonably Available
Property insurance premiums
Amounts placed in escrow
Charges paid to third-party service providers not included on written list
TRID SUMMARY OF CHANGES
Applications taken prior to October 3, 2015
Applications taken on or after October 3, 2015
GFE,ECOA Appraisal/Valuation Notice, Notice of Servicing Transfer.
Loan Estimate (LE) replaces these disclosures.
RESPA "Settlement Cost Booklet" provided to borrowers
CFPB"Your Home Loan Toolkit" booklet provided to borrowers
Definition of Application
Applicant Name, Income, SSN, Property Address, Property Value, Loan Amount, Any other item lender requires (7th Catchall).
7th Catchall removed
Definition of Business Day for Initial Loan Estimate
Business day is any day in which the creditor is open to the public for carrying out substantial all of its business functions.
If you are a mortgage broker or a correspondent lender brokering a loan to a wholesale lender you will follow the wholesale lenders' days they are open for business and not yours.
7-day waiting period from initialTIL to close date measured fromCREDITOR's TIL.
7-day waiting period measured from initial LE regardless of whether provided by broker or creditor.
Revised GFE/TIL upon a valid Change of Circumstance (COC).
Revised LE upon valid Change of Circumstance. IfCOC results in increased fees in 10% tolerance category, AM may notredisclose fees in this category to reset tolerance to be used at closing unless change results in an increase of more than 10%.
RevisedGFE upon valid Change of Circumstance (COC). Must be issued day prior to closing.
Revised LE upon valid Change of Circumstance (COC). Last revised LE must be RECEIVED by borrower(s) at least 4 business days prior to the issuance of the CD. Note: IfCOC occurs after issuance of CD, revised LE CANNOT be issued.
Zero Tolerance, 10% Tolerance and May Change categories
Zero Tolerance, 10% Tolerance and May Change categories. NOTE: determination of which category a particular fee belongs includes determination of whether or not a borrower was allowed to shop for a particular service. This results in changes such as appraisal, credit report, up front guaranty fees, etc now being in Zero Tolerance category.
Lender Paid Broker Compensation
Must disclose on GFE box 1 with offsetting lender credit in box 2. Similarly disclosed on HUD-1 at closing in lines 801/802.
Must NOT be disclosed on LE either as fee nor as credit. However, Lender Paid Broker Comp is disclosed on CD in the "paid by other" column.
HUD-1 and final TIL provided to borrower(s).
Closing Disclosure (CD) provided to borrower(s)
Closing Disclosure Timing
Provided no later than at closing.
Must be provided to all borrowers and any person with rescission rights no later than 3 business days prior to closing.