https://www.consumerfinance.gov/abo...gage-disclosures-for-construction-loans/1. Can someone please explain this to me?
2. Can you also explain why the ICBA, which is supposed to be an advocate of banking industry is suggesting a test that would basically require an entire re-write of the TRID disclosure rules? e.g.: " We are proposing to modify/expand the current Loan Estimate and Closing Disclosure to include improved construction phase detail, construction cost breakdown, and improved disclosure regarding the consumer's permanent loan financing."
3. Even if this "test" moves forward, can someone let me know what major document preparation provider is going to agree to work on this without a substantial upfront development payment?
This really has me totally confused.
I just do not understand the following statements put forth by the ICBA:
Since construction-to-permanent loans combine what was traditionally a commercial lending product with a consumer mortgage, the 2013 rule imposed additional requirements, resulting in compliance risks that were difficult for many lenders to manage. As a result, many of these lenders exited the consumer construction lending business and only focused on lending to builders or developers through their commercial lending operations.
However, many community banks have expressed compliance concerns using the current disclosure regime for these loans and have therefore elected not offer them.
(If you read the proposal, I am not sure how this would be any easier to comply with?)
I don't get it either. I need to read up on this too.
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