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#1111833 - 01/15/09 07:09 PM
Re: Servicing Disclosure Revision
Helium
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Platinum Poster
Joined: Jan 2005
Posts: 811
Pacific NW
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We use Lasor Pro and have begun using the new servicing disclosure. The software provides a box for additional verbage. Is any other users of LP adding in addional verbage? If so, what are you adding in? Is the form as it is all that is needed, other than choosing a box?
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#1111865 - 01/15/09 07:28 PM
Re: Servicing Disclosure Revision
dg
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Diamond Poster
Joined: Sep 2008
Posts: 2,474
Midwest
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Is there a new time frame of providing the disclosure? I tell the Loan Officers to provide it at application. This is our generaly policy. We are retaining a copy in file for our records but are not having the client sign.
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#1111867 - 01/15/09 07:30 PM
Re: Servicing Disclosure Revision
ahkcompliance
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Platinum Poster
Joined: Aug 2006
Posts: 879
Dallas, TX
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Yes, you now have three days to provide it like the other Early Disclosures.
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#1111872 - 01/15/09 07:36 PM
Re: Servicing Disclosure Revision
Ray_
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Diamond Poster
Joined: Sep 2008
Posts: 2,474
Midwest
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Does it matter if it is a face to face interview?
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#1111881 - 01/15/09 07:43 PM
Re: Servicing Disclosure Revision
ahkcompliance
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Platinum Poster
Joined: Aug 2006
Posts: 879
Dallas, TX
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No it doesn't. That language has been deleted effective 1/16/09.
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#1111883 - 01/15/09 07:44 PM
Re: Servicing Disclosure Revision
ahkcompliance
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Member
Joined: Jan 2008
Posts: 61
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Am I right in thinking that there is no longer any requirement for disclosing the PERCENTAGE of loans for which we transfer servicing? I have a new investor questioning why we don't disclose the percentage.
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#1111936 - 01/15/09 08:48 PM
Re: Servicing Disclosure Revision
QCL
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100 Club
Joined: Nov 2004
Posts: 237
USA
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Required use was the only provision delayed until April.
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#1112211 - 01/16/09 01:28 PM
Re: Servicing Disclosure Revision
Amos
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Diamond Poster
Joined: Oct 2002
Posts: 1,027
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So, to put it simply, we don't have to use the new servicing disclosure until April, right??
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#1112257 - 01/16/09 02:24 PM
Re: Servicing Disclosure Revision
HR Banker
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Power Poster
Joined: Nov 2001
Posts: 7,983
FINALLY ABOVE the gnat line
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I thought the publication by HUD indicated that only the "definition of required Use" provision was delayed until April because of the lawsuit. That provision is separate from the servicing disclosure which is supposed to be in use by today.
_________________________
"Once you learn to read, you will be forever free." - Frederick Douglass
My Opinion Only.
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#1112264 - 01/16/09 02:28 PM
Re: Servicing Disclosure Revision
waldensouth
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10K Club
Joined: Nov 2002
Posts: 20,654
The Swamp
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that's my understanding as well, walden.
_________________________
My opinion only. Not legal advice. Say you'll haunt me - Stone Sour
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#1115413 - 01/22/09 08:25 PM
Re: Servicing Disclosure Revision
QCL
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Power Poster
Joined: Aug 2001
Posts: 7,351
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You should check the box for what you "intend" to do. You're not bound to it.
_________________________
The more you sweat in training, the less you bleed in battle.......
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#1115420 - 01/22/09 08:28 PM
Re: Servicing Disclosure Revision
swiggles
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10K Club
Joined: Jul 2003
Posts: 17,395
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The first one is the safe bet/catchall imho. You 'may' transfer the servicing...then again, you 'may' not. This cya's ya' no matter what.
btw, if you read up you'll see Dan's example where he uses just the one option, not the multiple choice. Then you don't have to worry about who checks what 'cause you're not giving them a choice!
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#1115432 - 01/22/09 08:33 PM
Re: Servicing Disclosure Revision
QCL
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Diamond Poster
Joined: Nov 2004
Posts: 2,307
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Appendix MS-1 to Part 3500 (Regulation X) states the following:
"INSTRUCTIONS TO PREPARER: Insert the date and select the appropriate language under “Servicing Transfer Information.” The model format may be annotated with further information that clarifies or enhances the model language."
I think if your form lists all three items and precedes them with a box or line that you would check to indicate which one applies you should be okay. You shouldn't be checking more than one box on the form for a particular customer. For most of our loans, we will be checking the first box. We sometimes originate loans under a special state program where once we originate the loan it is sold with servicing released. For these loans, we would be checking the last box.
_________________________
Opinions expressed are my own and not necessarily those of my employer. They are not legal advice.
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#1115441 - 01/22/09 08:36 PM
Re: Servicing Disclosure Revision
Truffle Royale
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Power Poster
Joined: Aug 2001
Posts: 7,351
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The first one is the safe bet/catchall imho. You 'may' transfer the servicing...then again, you 'may' not. This cya's ya' no matter what.
btw, if you read up you'll see Dan's example where he uses just the one option, not the multiple choice. Then you don't have to worry about who checks what 'cause you're not giving them a choice! This is in my ever-so-humble opinion...... Our Mortgage Center sells 99.999999% of their loans. I don't think that checking the catch-all box for applications submitted there would be accurate by any stretch of the imagination, because we DO intend to sell all of 'em. Occasionally, however, an investor might reject one (for whatever reason) and we'll have to keep it in house. On the flip-side, loans originated from applications taken by "non-mortgage-center-lenders" will never be sold. That is not our intent and historical data would indicate that this is the case. I don't think the catch all statement would be an accurate representation for these loans. Of course, your bank may operate in an entirely different manner, whereby you truly don't know, at application, what your intent might be.
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The more you sweat in training, the less you bleed in battle.......
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