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?

That is what we are planning on doing.

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.

Thanks John.

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?

No, and you never were. It was always within 3 days of application.

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?

Yes, nothing changed on the ARM other than the content with the new timing requirements for the rate change notices.

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?

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.

Awesome, thanks for your help.