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#2137270 - 07/07/17 05:55 PM Final TRID Rule
rlcarey Offline
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Galveston, TX
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TRID - TILA/RESPA Integrated Disclosures Rule
#2137271 - 07/07/17 05:59 PM Re: Final TRID Rule rlcarey
RR Joker Offline
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So it's a final with another proposal attached? crazy
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#2137287 - 07/07/17 07:28 PM Re: Final TRID Rule rlcarey
crcmnot Offline
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....and only 560 pages of light reading!

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#2137299 - 07/07/17 08:18 PM Re: Final TRID Rule crcmnot
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I just saw a headline that says the final rule does not resolve the black hole issue.
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#2137300 - 07/07/17 08:42 PM Re: Final TRID Rule rlcarey
rlcarey Offline
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I think they kicked it down into the other proposal - but I wasn't going to read that until I finished the final rule. 400+ pages to go....
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#2137302 - 07/07/17 08:49 PM Re: Final TRID Rule rlcarey
RebekahL CRCM Offline
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So you'll have a nice executive summary for us when you arrive 7/30?! crazy sick laugh
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#2137306 - 07/07/17 09:49 PM Re: Final TRID Rule rlcarey
Darth HMDA, CRCM, CAMS Offline
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Read through sections of the NEW proposed rule, specifically those relating to the black hole.. still don't understand why they couldn't have just finalized as proposed. I understand the concern that lenders will start sending out CD's much earlier in the process if the four day restriction is removed but we still have to abide by the CC rules triggering redisclosure/tolerance resets..

my head hurts... smile
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#2137307 - 07/07/17 10:00 PM Re: Final TRID Rule rlcarey
crcmnot Offline
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I got up to page 131......I have fallen into the black hole!

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#2137328 - 07/10/17 12:29 PM Re: Final TRID Rule rlcarey
Dan Persfull Offline
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I understand the concern that lenders will start sending out CD's much earlier

We have lenders in this area that provide the CD the same or next day as they do the LE. As I've read the proposal, and I'm only about half way through it, I no longer see the purpose of the LE.
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#2137345 - 07/10/17 01:45 PM Re: Final TRID Rule rlcarey
raitchjay Offline
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Do ya'll read all 560 pages.....??? What parts are good to skip, if any?
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#2137350 - 07/10/17 02:31 PM Re: Final TRID Rule rlcarey
Dan Persfull Offline
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I haven't started the revision yet. I just skimmed through the 40 + pages of the proposal. I'm doing quarterly audits and I'm on vacation the week of the 24th so I won't start reading the revision until at least the first of August when I get back.
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#2137354 - 07/10/17 02:32 PM Re: Final TRID Rule Dan Persfull
ccman Offline
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Exactly! More quantity over quality! This group is the black hole!

Perfect case of analysis paralysis!

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#2137362 - 07/10/17 03:21 PM Re: Final TRID Rule rlcarey
raitchjay Offline
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This makes no sense to me:

In the case of a construction-permanent loan that a creditor
chooses to disclose as multiple transactions, the creditor must allocate to the construction
transaction finance charges under § 1026.4 and points and fees under § 1026.32(b)(1) that would
not be imposed but for the construction financing. If a creditor charges separate finance charges
under § 1026.4 and points and fees under § 1026.32(b)(1) for the construction phase and the
permanent phase, such fees and charges must be allocated to the phase for which they are
charged. All other finance charges under § 1026.4 and points and fees under § 1026.32(b)(1)
must be allocated to the permanent financing. Using the “but for” allocation for these amounts
when separate disclosures are provided for the phases of a construction-permanent loan will
allow creditors to determine more accurately whether the permanent phase is a high-cost
mortgage or higher-priced mortgage loan or qualified mortgage.



It seems to be saying "finance charges and points and fees must be disclosed on the construction phase"...but then "finance charges and points and fees must be disclosed on the perm phase". I'm sure i'm missing something.
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#2137365 - 07/10/17 03:24 PM Re: Final TRID Rule rlcarey
raitchjay Offline
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OK
Ok...i guess the key phrase is "but for the construction financing".
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#2137368 - 07/10/17 03:32 PM Re: Final TRID Rule rlcarey
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The point they are making is that you should allocate the fees based on the phase they pertain to. I think people were circumventing limits by charging fees on the permanent loan at time of construction, if I had to take a WAG at it.

I am VERY happy to see we will be able to use the land PLUS improvements on construction phases. Only disclosing land until the CD of the permanent phase never has made any sense to me. I wish they'd do the same for titled manufactured home/land deals. I understand titled = chattel property and not RE, but still, it would make more 'logical' sense.
Last edited by RR Joker; 07/10/17 03:33 PM.
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#2137373 - 07/10/17 03:50 PM Re: Final TRID Rule rlcarey
raitchjay Offline
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I think they were doing the opposite.....putting all the fees on the construction phase, which if for 12 months or less was exempt from ATR and HOEPA. That paragraph is just a bit confusing to read.
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#2137377 - 07/10/17 03:52 PM Re: Final TRID Rule rlcarey
raitchjay Offline
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Oh...i just re-read your sentence....that's what you said too. Sorry.
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#2137386 - 07/10/17 04:46 PM Re: Final TRID Rule Dan Persfull
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Originally Posted By Dan Persfull
I understand the concern that lenders will start sending out CD's much earlier

We have lenders in this area that provide the CD the same or next day as they do the LE. As I've read the proposal, and I'm only about half way through it, I no longer see the purpose of the LE.


That's how I essentially read it... We have always stressed the importance of NOT sending out the CloD too soon... it will be interesting to see what happens after this is finalized.

Never a dull moment... smile
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#2137539 - 07/11/17 05:31 PM Re: Final TRID Rule rlcarey
crcmnot Offline
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There has been some discussion on the boards regarding construction-only loans and where the construction holdback funds go on the LE/CD. In reading pages 172-175 of the new rule, can someone tell me if the CFPB is now stating that the construction holdback fund should no longer go in Section H as other costs?

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#2137547 - 07/11/17 06:02 PM Re: Final TRID Rule rlcarey
rlcarey Offline
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Yup - that is what they are saying
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#2137553 - 07/11/17 06:20 PM Re: Final TRID Rule rlcarey
crcmnot Offline
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Dagnabit! That is what I thought it said. Now to change my process back to the way we were doing it previously. Got to love 'final' rules. Thanks Randy!

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#2137559 - 07/11/17 06:33 PM Re: Final TRID Rule rlcarey
raitchjay Offline
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I haven't gotten that far...so they are saying it needs to go in K., right?
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#2137560 - 07/11/17 06:33 PM Re: Final TRID Rule rlcarey
raitchjay Offline
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OK
I hope so...that's where we already put them.
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#2137603 - 07/11/17 08:17 PM Re: Final TRID Rule rlcarey
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I hope so too, but I could sure swear I had read the opposite and have not been happy about it either. I sure hope it was just my dyslexia at work! smile
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#2137623 - 07/11/17 09:36 PM Re: Final TRID Rule rlcarey
raitchjay Offline
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OK
What did you think it said?
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