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#2249641 - 02/23/21 11:55 PM Homestead Credit and CD
JobSecurity Offline
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Joined: Oct 2009
Posts: 604
What is the correct way to disclose the taxes and insurance on the CD when the homestead credit zeros out the tax bill? Do we put zero but check that it is included? Is the best way to disclose the full tax and not subtract the credit since the customer has to make the effort to secure the credit. Did not fund a thread on this. Thanks!

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TRID - TILA/RESPA Integrated Disclosures Rule
#2249672 - 02/24/21 04:41 PM Re: Homestead Credit and CD JobSecurity
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
I think you have to make your disclosures based on the facts as they are at the time. If the consumer will have to apply for the credit, presumably after they take title, the facts as they exist up to and through the closing are that taxes will be owed. So you disclose accordingly.

There would certainly be nothing wrong with informing the consumer about the homestead credit and even how to go about applying for it, but they can't do that until the own the property, so the disclosures should reflect facts as the exist today.
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John S. Burnett
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#2249674 - 02/24/21 04:46 PM Re: Homestead Credit and CD JobSecurity
John Burnett Offline
10K Club
John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
Put another way, you should not assume the consumer will apply for the homestead credit.
Last edited by John Burnett; 02/24/21 04:46 PM. Reason: typo
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John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8

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