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#2040676 - 09/25/15 06:37 PM disclosures we can delete
Charles Everson Offline
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Charles Everson
Joined: Mar 2007
Posts: 149
Overland Park, Kansas
Now that the LE lists verbiage that replaces the old RESPA Servicing Disclosure, we are wondering if there are any additional disclosures from today's world that we can omit. Thoughts?
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TRID - TILA/RESPA Integrated Disclosures Rule
#2040691 - 09/25/15 07:12 PM Re: disclosures we can delete Charles Everson
RR Joker Offline
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RR Joker
Joined: Nov 2002
Posts: 20,656
The Swamp
Appraisal notice comes to mind.
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#2040692 - 09/25/15 07:13 PM Re: disclosures we can delete Charles Everson
#Just Jay Offline
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#Just Jay
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Cheeseheadland
Only two I can think of...
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#2040693 - 09/25/15 07:13 PM Re: disclosures we can delete Charles Everson
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
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Just keep the appraisal notice in place for those situations not receiving the TRID disclosures.
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#2040710 - 09/25/15 07:53 PM Re: disclosures we can delete Charles Everson
John Burnett Offline
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John Burnett
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Cape Cod
Such as business-purpose closed-end loans secured by a first lien on a dwelling or any closed-end loan secured by a first line on a dwelling that's not real estate.
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#2040718 - 09/25/15 08:11 PM Re: disclosures we can delete Charles Everson
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
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Or an application turned down before the disclosures are sent.
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HMDA/CRA Training/Consulting/Mapping
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#2040721 - 09/25/15 08:16 PM Re: disclosures we can delete Charles Everson
John Burnett Offline
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John Burnett
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Cape Cod
Oops, Kathleen -- There is no exception for the Right to Appraisal Copy exception for early denials/withdrawals. But we can include the Loan Estimate and the Servicing Disclosure and the List of Homeowner's Counseling providers among those that don't need to be given if the application is "terminated" before the third business day.
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#2040722 - 09/25/15 08:19 PM Re: disclosures we can delete Charles Everson
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
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I think we are talking at cross purposes...I was adding on to "when they won't get TRID disclosures" and denials, etc. in early days are in that category. I guess I wasn't clear.

Last edited by Kathleen B; 09/25/15 08:20 PM.
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Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy
www.kaybeescomplianceinsights.com

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