Do we have to use the specific Loan Estimate and Closing Disclosure by transaction or can we use the LE for fixed rate loan for all our loans (we don't have ARM, balloon payment or negative am. Use the basic one for purchase, refinances and equity cash out?

Same question on Closing Disclosure. There are so many examples of closing disclosure depending on if consumer has simultaneous 2nd lien, if funds are paid outside of closing or closing costs are higher, etc. Do we really have to use these specific forms according to the transaction or can we just use the fixed rate loan form?

We have tossed this question around, also. We offer only fixed rate loans, but the LE an CD seem to lean towards ARMs info. Anyone have an understanding on how the LE and CD should be used in these cases? With 56% respondents saying they are on top of the TRID per the poll, how would you respond to this question? thanks.

We participated but how do you view the poll?

My understanding is that you have to use the form that applies to the structure of the loan. We are still waiting to see how our LOS is going to handle this. Our equity loan system is able to produce dynamic docs, while our mortgage system will not. I assume we will need to build forms packages based on the structure of each loan product on our mortgage LOS.

Hopefully, you are going to be using a mortgage origination/software package that, based upon the information supplied for your products and a particular loan, will produce the appropriate documents. This not like days of old where you select the pink form or the blue form off the shelf. These are automated dynamic forms that are very specifically tailored to a product and transaction.

We offer only fixed rate loans, but the LE an CD seem to lean towards ARMs info. Anyone have an understanding on how the LE and CD should be used in these cases?


If the disclosure is not applicable, such as the ARM loan disclosures, then they are not disclosed on the LE or CD.

http://www.bankersonline.com/regs/12-1026/12-1026-037.html

http://www.bankersonline.com/regs/12-1026/12-1026-038.html