Early RESPA Disclosures Reg X requires these disclosures to be provided or mailed 1024.6 Settlement Book within 3 business day after application: – 1024.7 GFE Settlement Cost Booklet (first lien purchase) – 1024.21 MSDS refinancings) (“Your on Home Loan Tool Kit” – List of Providers Appendix C 10/3/15 for TRID) – Counseling List - 1024.20 Good Faith Estimate (LOAN ESTIMATE) List of service providers (if borrower can shop for required 3rd party settlement service) Mortgage Servicing Statement (only on 1st lien mortgages) List of HUD-approved homeownership counseling organizations CFPB Guidance An Interpretive Rule issued November 14, 2013 instructs banks to provide a list of the 10 organizations closest to the applicant’s location. To find this list, go to the CFPB’s website (www.consumerfinance.gov) and conduct a search for counseling.” Simply enter the “homeownership applicant’s zip code to obtain the appropriate list. MUST BE UPDATED EVERY 30 DAYS. Denied/Withdrawn & definition If the application is denied or withdrawn within the of business day period, these early disclosures are not required. Under RESPA, a business day is a day on which the offices of the bank are open to the public for carrying on substantially all of the bank's business functions. PRIOR TO CLOSING– NINE Issues Ability to options Flood Insurance Appraisal or Valuation Special HPML appraisal High-Cost Mortgage Rules (HOEPA) Corrected Early Truth in Lending Disclosure HPML Escrow Account Homeownership Counseling Adverse Action EFFECTIVE 10/3/15 FOR COVERED APPLICATIONS THE CLOSING DISCLOSURE MUST BE RECEIVED 3 BUSINESS DAYS PRIOR TO CLOSING! SEE CHECLIST IN THE APPENDIX”. The Closing Disclosure is considered “TRID if mailed 3 days prior to the required date; by proof of e-sign receipt, or “received” proof of overnight delivery, or proof that it was delivered in person. NOTE: - See the Checklist” pages in the Appendix for more information for TRID Loans “Loan
Early RESPA Disclosures 1024.6 – Settlement Book 1024.7 – GFE 1024.21 – MSDS List of Providers – Appendix C Counseling List - 1024.20 Reg X requires these disclosures to be provided or mailed within 3 business day after application: Settlement Cost Booklet (first lien purchase) refinancings) (“Your Home Loan Tool Kit” on 10/3/15 for TRID) Good Faith Estimate (LOAN ESTIMATE) List of service providers (if borrower can shop for required 3rd party settlement service) Mortgage Servicing Statement (only on 1st lien mortgages) List of HUD-approved homeownership counseling organizations CFPB Guidance An Interpretive Rule issued November 14, 2013 instructs banks to provide a list of the 10 organizations closest to the applicant’s location. To find this list, go to the CFPB’s website (www.consumerfinance.gov) and conduct a search for “homeownership counseling.” Simply enter the applicant’s zip code to obtain the appropriate list. MUST BE UPDATED EVERY 30 DAYS. Denied/Withdrawn & definition of business day If the application is denied or withdrawn within the period, these early disclosures are not required. Under RESPA, a business day is a day on which the offices of the bank are open to the public for carrying on substantially all of the bank's business functions. PRIOR TO CLOSING– NINE Issues Ability to options Flood Insurance Appraisal or Valuation Special HPML appraisal High-Cost Mortgage Rules (HOEPA) Corrected Early Truth in Lending Disclosure HPML Escrow Account Homeownership Counseling Adverse Action EFFECTIVE 10/3/15 FOR COVERED APPLICATIONS THE CLOSING DISCLOSURE MUST BE RECEIVED 3 BUSINESS DAYS PRIOR TO CLOSING! SEE “TRID CHECLIST IN THE APPENDIX”. The Closing Disclosure is considered “received” if mailed 3 days prior to the required date; by proof of e-sign receipt, or proof of overnight delivery, or proof that it was delivered in person. NOTE: - See the “Loan Checklist” pages in the Appendix for more information for TRID Loans
MLOIIHOAR081815.docx