Thread Options
#2036464 - 08/31/15 04:51 PM Loan Estimate and other initial disclosures
Patricia Offline
Gold Star
Joined: Mar 2011
Posts: 327
Kansas
Before the new rules the bank sent a cover letter for the initial disclosures i.e. Early TIL, GFE, Provider List, Settlement Booklet, Right to Receive Copy of Appraisal etc.

With the new rules can we still send other initial disclosures with the LE?

Return to Top
TRID - TILA/RESPA Integrated Disclosures Rule
#2036470 - 08/31/15 05:08 PM Re: Loan Estimate and other initial disclosures Patricia
JWills, CRCM Offline
Diamond Poster
JWills, CRCM
Joined: May 2013
Posts: 1,726
The Mitten State
That is what we are planning on doing.
_________________________
Nonsense wakes up the brain cells.

--Dr. Seuss

Return to Top
#2036531 - 08/31/15 07:54 PM Re: Loan Estimate and other initial disclosures Patricia
John Burnett Offline
10K Club
John Burnett
Joined: Oct 2000
Posts: 39,333
Cape Cod
Yes, you can (and should) send the provider list, settlement costs booklet (when required for a TRID loan, you'll use the new "Home Toolkit"), appraisal right notice, in the same mailing, along with a cover letter (optional, but certainly a good idea) that explains how to provide intent to proceed and what documents (and fees) need to be sent, etc.
_________________________
John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8

Return to Top
#2036549 - 08/31/15 08:38 PM Re: Loan Estimate and other initial disclosures Patricia
Patricia Offline
Gold Star
Joined: Mar 2011
Posts: 327
Kansas
Thanks John.

Return to Top
#2043695 - 10/09/15 08:27 PM Re: Loan Estimate and other initial disclosures Patricia
Hunter Offline
New Poster
Joined: Sep 2015
Posts: 10
In the pre-TRID initial disclosures we were required to provide a consumer with the Servicing Disclosure at application. So if the customer were sitting in front of you with a new application you would provide them with this disclosure. And of course if the application was taken via the phone, internet, emailed or faxed we would include this disclosure with the other disclosure within three days of the application.

With the new TRID rules the servicing disclosure is included in the Loan Estimate which should be provided to the customer within three days of receiving a complete application.

Are we still required to provide this disclosure at application?

Return to Top
#2043714 - 10/09/15 08:56 PM Re: Loan Estimate and other initial disclosures Patricia
John Burnett Offline
10K Club
John Burnett
Joined: Oct 2000
Posts: 39,333
Cape Cod
No, and you never were. It was always within 3 days of application.
_________________________
John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8

Return to Top
#2043735 - 10/09/15 10:13 PM Re: Loan Estimate and other initial disclosures Patricia
CRL Offline
Platinum Poster
CRL
Joined: Sep 2003
Posts: 562
The ARM disclosure is still required, correct?

And I'm not sure, but isn't it the ARM disclosure that we're supposed to give at time of application if the application was taken face to face? Maybe that's what folks are remembering that needed to be "at application" if in person?

Return to Top
#2043736 - 10/09/15 10:26 PM Re: Loan Estimate and other initial disclosures Patricia
Compl101TX Offline
Gold Star
Compl101TX
Joined: Aug 2010
Posts: 378
W. TX
Yes, nothing changed on the ARM other than the content with the new timing requirements for the rate change notices.
_________________________
My opinion only.
AVP-Compliance

Return to Top
#2044878 - 10/19/15 04:52 PM Re: Loan Estimate and other initial disclosures Patricia
morirse de risa Offline
100 Club
Joined: Feb 2009
Posts: 238
Midwest
Our ARM disclosure for C1M is printing with the early disclosure date. We need this to print with an application date, as it is an application disclosure. Any C1M users know how to get this to work?

Return to Top
#2044892 - 10/19/15 05:41 PM Re: Loan Estimate and other initial disclosures Patricia
RR Joker Offline
10K Club
RR Joker
Joined: Nov 2002
Posts: 20,644
The Swamp
You need to change the date in document data each time a date needs to be unique.

We have the app takers put their date in there for that purpose, then the TRID processor puts in the new date that earlies are prepared, and so forth.
_________________________
My opinion only. Not legal advice.

Say you'll haunt me - Stone Sour

Return to Top
#2044924 - 10/19/15 06:51 PM Re: Loan Estimate and other initial disclosures Patricia
morirse de risa Offline
100 Club
Joined: Feb 2009
Posts: 238
Midwest
Awesome, thanks for your help.

Return to Top