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#2137270 - 07/07/17 05:55 PM
Final TRID Rule
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10K Club
Joined: Jul 2001
Posts: 83,227
Galveston, TX
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#2137287 - 07/07/17 07:28 PM
Re: Final TRID Rule
rlcarey
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Joined: Sep 2016
Posts: 351
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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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Joined: Nov 2004
Posts: 2,307
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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
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Joined: Jul 2001
Posts: 83,227
Galveston, TX
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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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#2137306 - 07/07/17 09:49 PM
Re: Final TRID Rule
rlcarey
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Joined: Dec 2013
Posts: 1,399
CA
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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...
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#2137307 - 07/07/17 10:00 PM
Re: Final TRID Rule
rlcarey
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Joined: Sep 2016
Posts: 351
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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
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Joined: Aug 2002
Posts: 47,517
Bloomington, IN
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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
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Joined: Oct 2009
Posts: 9,088
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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
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Joined: Aug 2002
Posts: 47,517
Bloomington, IN
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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
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Platinum Poster
Joined: Sep 2007
Posts: 937
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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
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Joined: Oct 2009
Posts: 9,088
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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
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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 Swamp
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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
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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
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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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Diamond Poster
Joined: Dec 2013
Posts: 1,399
CA
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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. 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...
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#2137539 - 07/11/17 05:31 PM
Re: Final TRID Rule
rlcarey
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Gold Star
Joined: Sep 2016
Posts: 351
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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
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10K Club
Joined: Jul 2001
Posts: 83,227
Galveston, TX
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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
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Gold Star
Joined: Sep 2016
Posts: 351
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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
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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
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I hope so...that's where we already put them.
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#2137623 - 07/11/17 09:36 PM
Re: Final TRID Rule
rlcarey
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Joined: Oct 2009
Posts: 9,088
OK
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What did you think it said?
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