Regulatory Changes with TRID:
Home Loan Tool Kit-
The Home Loan Toolkit replaces the Settlement Cost Booklet when TRID goes into effect. This should be delivered to the Consumer with the Loan Estimate.
The Initial Loan Estimate must be delivered no later than 3 business days after receiving the loan application. In addition, the Loan Estimate must be delivered 7 business days before the loan consummation. The 3 business days includes any day the client’s office is open for business (typically Monday through Friday). The 7 business days includes all calendar days except Sundays and Legal Holidays.
Change of Circumstance-
Clients are only allowed to increase an estimated charge due to one of the six valid reasons noted in the rule. If an updated LE is issued the Initial LE, Updated LE and documentation explaining the change are required.
The Closing Disclosure must be received by the consumer no less than 3 business days before loan consummation. The 3 business days includes all calendar days except Sundays and Legal Holidays.
If delivered in person, Gateway requires either the Closing Disclosure or an Acknowledgement Receipt signed by the Consumer. If mailed, an additional 3 business days for receipt from the mailing date will be added to confirm Consumer delivery. If electronic delivery, Gateway requires documentation supporting receipt of the CD. Also proof of the Consumer’s consent to receive Disclosures electronically. Examples of documentation to support receipt include acknowledgement of receipt signed by every Consumer, separate courier receipt for overnight delivery to every Consumer, dated response from every Consumer specifically stating the Closing Disclosure was received electronically. These must be for each Consumer individually.
Closing Disclosure also must be signed at the loan consummation. We strongly recommend the Closing Disclosure signed at consummation is marked “Final”.
Changes After Initial CD Is Issued-
Gateway will require the CD be re-disclosed and a new 3 business day waiting period for the following changes:
· APR increases by more than .125% on fixed or .25% on ARM loans
· Loan program changes
Gateway will not purchase loans where the borrower has waived any of the required disclosure times.
Post Consummation Cures-
Tolerance cures must be completed within 60 calendar days after consummation. Gateway requires a copy of the following documents: Corrected CD, check to Consumer, Letter of Explanation to the Consumer, and Overnight Label to the Consumer.