Skip to content
BOL Conferences
Thread Options
#2176833 - 05/04/18 09:13 PM Mandatory Implementation Date for Alt LE/C
CMSIngenue Offline
100 Club
Joined: Jan 2013
Posts: 154
Has the CFPB announced a mandatory implementation date for the Alt LE/CD? Thank You

Return to Top
TRID - TILA/RESPA Integrated Disclosures Rule
#2176843 - 05/04/18 10:04 PM Re: Mandatory Implementation Date for Alt LE/C CMSIngenue
rlcarey Online
10K Club
rlcarey
Joined: Jul 2001
Posts: 83,229
Galveston, TX
Not sure what you mean by the Alt LE/CD. There are no new forms.
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

Return to Top
#2176852 - 05/04/18 10:38 PM Re: Mandatory Implementation Date for Alt LE/C CMSIngenue
Cliff Johnson Offline
Junior Member
Joined: Sep 2015
Posts: 46
They don't mandate it, it is GSE driven. Here's an excerpt from the TRID 2.0 commentary

A refinance transaction may be disclosed using the optional alternative
calculating cash to close table under § 1026.37(h)(2), but use of that table is not required.
However, if the creditor previously disclosed the optional alternative calculating cash to close
table under § 1026.37(h)(2), the alternative calculating cash to close table must also be disclosed
under § 1026.38(e). At the same time, secondary market investors may decide, as a business
practice, to impose additional requirements, such as requiring the use of the alternative
disclosures for refinance transactions.

Return to Top
#2176854 - 05/04/18 10:54 PM Re: Mandatory Implementation Date for Alt LE/C CMSIngenue
rlcarey Online
10K Club
rlcarey
Joined: Jul 2001
Posts: 83,229
Galveston, TX
That is true, if you are currently required to provide a UCD file to the GSE's you are going to get an error (which is not yet a fatal error, but they will make it so sometime in the future) if you use a standard LE/CD on a transaction that does not involve a seller.
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

Return to Top
#2176858 - 05/05/18 12:26 AM Re: Mandatory Implementation Date for Alt LE/C CMSIngenue
CMSIngenue Offline
100 Club
Joined: Jan 2013
Posts: 154
Just to confirm: The GSEs require the Alternative LE/CD on transactions that do not involve a seller but it is not a fatal error. So as a lender you can get away with not complying for now?

Return to Top
#2176862 - 05/05/18 11:16 AM Re: Mandatory Implementation Date for Alt LE/C CMSIngenue
rlcarey Online
10K Club
rlcarey
Joined: Jul 2001
Posts: 83,229
Galveston, TX
On non-seller (e.g., refinance) transactions, do the GSEs require the use of the “Alternate” form, Form H-25(E), published by the CFPB? (Refer to Federal Register vol. 78, No. 251 on p. 80187).


Both GSEs require use of form H-25(E) for all refinance transactions on the loans they acquire (refer to Federal Register website for additional details on this regulation). If a non-seller transaction is submitted on the “Model” form, the GSE collection systems will issue warning messages at the outset of the mandate and will not prevent a submission from being considered “successful.” However, the warnings may be changed to a hard stop at a later date. More information will be provided by the GSE regarding the timeframe for these hard stops.
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

Return to Top