Premiere Mortgage Services Inc. - Dana Bain


September 30th, 2015 1:18 PM by Robin Bain

0% Tolerance

Lender charges and credits

Mortgage broker's charges

Paid to affiliate of creditor or broker

Unaffiliated third party if shopping not allowed

Transfer taxes

10% Aggregate Increase

Unaffiliated third party if shopping allowed but consumer does not shop

Recording fees

Best Information Reasonably Available

Prepaid interest

Property insurance premiums

Amounts placed in escrow

Charges paid to third-party service providers not included on written list






Effective Date

Applications taken prior to October 3, 2015

Applications taken on or after October 3, 2015

Initial Disclosures

GFE,ECOA Appraisal/Valuation Notice, Notice of Servicing Transfer.

Loan Estimate (LE) replaces these disclosures.

Required Application

Disclosure Booklet

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.

Tolerance Categories

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.

Closing Disclosures

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.


Posted in:General and tagged: TRID
Posted by Robin Bain on September 30th, 2015 1:18 PM


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