Hi All,

Does the Home Loan Tool Kit need to be printed in color?
Does the Home Loan Tool Kit be given as an early disclosure?

1026.19(g)(1)(i) The creditor shall deliver or place in the mail the special information booklet not later than three business days after the consumer's application is received. However, if the creditor denies the consumer's application before the end of the three-business-day period, the creditor need not provide the booklet. If a consumer uses a mortgage broker, the mortgage broker shall provide the special information booklet and the creditor need not do so.

Commentary to 1026.19(g)(2) 1. Reproduction. The special information booklet may be reproduced in any form, provided that no changes are made, except as otherwise provided under § 1026.19(g)(2). See also comment 19(g)(2)-3. Provision of the special information booklet as a part of a larger document does not satisfy the requirements of § 1026.19(g). Any color, size and quality of paper, type of print, and method of reproduction may be used so long as the booklet is clearly legible.

So the answers to your questions are No and Yes, in that order.

Did anyone else notice the CFPB revised the Toolkit as of August 2015? It appears to be all of the same data from the initial toolkit, just with a picture on the front and some formatting differences. I cannot find any guidance to address this other than permissible changes for lenders to add their logo - but that's not what I'm asking. Are we still ok to use the version they released (and we ordered 1000 booklets) in March 2015? Thanks in advance,

This booklet replaces the current HUD Settlement booklet, correct? Is it to be given to ALL applicants, or only those that are applying for purchase transactions?

Correct.

You are required to provide it to TRID loan applicants for first lien purchase-money loans involving a 1-4 family residential property. Reference Reg X 1024.6 and Reg Z 1026.19(g).

Did anyone notice the TOOLKIT is different than the initial TOOLKIT the CFPB published in March 2015? There is a picture of a house on the cover, #'s 2 and #3 are flipped in the new version and the back page shows August 2015. Anyone?

Is the Toolkit required in a Bridge Loan situation where we are taking the OLD home as collateral and funding money to purchase the NEW home, but the loan will only be secured by the OLD home? In other words, does the collateral property also need to be the property being purchased for the requirement of the Toolkit; or ANY property (1-4 SFR) as long as the purpose was to purchase a 1-4? This question has come up so need clarification on whether the collateral property matters for a purchase. Thanks!!

Old post. Hopefully someone will see it.... can a lender simply provide a link to the booklet??

I'm thinking nope. Must be hard copy.

They provided the online version for consumers to play with. You still have to provide the hard copy unless you go the E-SIGN route.

Is a signed disclosure required as evidence the borrower has received the Home Loan Toolkit? We provide the paper booklet to the borrower at the time of application. My QC company is hitting me up for a Home Loan Toolkit Disclosure. Any help would be appreciated. Thanks.

You don't need a signature for the delivery of this document any more than you needed a signature for the delivery of the HUD Settlement Costs Booklet. Most bank provide a cover letter with all early disclosures that indicate the attachments: LE, Toolkit, Counseling Agencies, etc.

The more that lenders go into überdocumentation mode, the deeper they dig a compliance hole of their own making. There are very few documents and disclosures that carry regulatory requirements for a consumer's acknowledgment signature. Unless you sell loans to investors who insist on borrowers' signatures, I suggest you resist the idea.

Is the Home Loan Tool Kit Booklet consider a disclosure where we would have to apply the e-sign/e-consent requirement.? For example, lender has the e-consent from the borrower delivers the 3 day disclosures by e-mail however, the mortgage broker delivers the Home Loan Tool Kit booklet by e-mail, does the mortgage broker need to comply with the e-consent requirements? Per the rule, If a consumer uses a mortgage broker, the mortgage broker shall provide the special information booklet and the creditor need not do so (section 1026.19(g)(1)(I)

Any required written disclosure cannot be just e-mailed to a customer and have to ever considered delivered.

Why are you not just providing it in your package since you do not appear to be relying on the broker for delivery of the LE. Then you would be covered no matter want he broker did.

Would the Home Loan Toolkit Booklet be required for a first lien home equity term loan? Thanks!

1026.19(g)(1)(iii) The creditor or mortgage broker need not provide the booklet to the consumer for a transaction, the purpose of which is not the purchase of a one-to-four family residential property

Thank you!