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#2050682 - 11/20/15 04:16 PM CD Loan Product
mdog76 Offline
Platinum Poster
Joined: Jan 2007
Posts: 645
On the closing disclosure, does the specific loan product have to be disclosed i.e. 7/1 Adjustable Rate or 5/1 Adjustable Rate? We have had two title companies tell us that their software will only allow them to list Adjustable Rate for the product.

Thank you.

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TRID - TILA/RESPA Integrated Disclosures Rule
#2050710 - 11/20/15 04:56 PM Re: CD Loan Product mdog76
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 39,785
Cape Cod
Then those title companies have failed to follow the requirements. The requirements as to the Closing Disclosure in section 1026.38(a)(5)(iii) clearly say you provide the Product description as required by 1026.37(a)(10).

Demand that the title company comply with the regulation or you'll have to find another way to get your CloDs prepared, correctly.
_________________________
John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8

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#2050715 - 11/20/15 05:13 PM Re: CD Loan Product mdog76
mdog76 Offline
Platinum Poster
Joined: Jan 2007
Posts: 645
Ok, thanks. That's kind of what I thought but wanted to verify.

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