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#2044817 - 10/19/15 01:20 PM Are the new TRID docs required for 2nd mtg loans?
BYC Baird Offline
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Joined: Oct 2015
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I assume that any junior mortgage lending for primary residences on a closed end product require the use of the new loan estimate and closing disclosure. I have not been able to find any direct information on it.

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TRID - TILA/RESPA Integrated Disclosures Rule
#2044822 - 10/19/15 01:33 PM Re: Are the new TRID docs required for 2nd mtg loans? BYC Baird
Skittles Offline
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Skittles
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TN
Yes - it applies to closed end consumer mortgage loans.
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#2044855 - 10/19/15 03:26 PM Re: Are the new TRID docs required for 2nd mtg loans? BYC Baird
Dan Persfull Offline
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Dan Persfull
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Bloomington, IN
I assume that any junior mortgage lending for primary residences on a closed end product require the use of the new loan estimate and closing disclosure.

Just so there is no misunderstanding. ANY closed-end consumer purpose loan secured by real property (dirt) regardless if that real property is land only, single or multiple family residential or commercial property the loan it subject to TRID regardless of lien position.
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#2044858 - 10/19/15 03:38 PM Re: Are the new TRID docs required for 2nd mtg loans? BYC Baird
RR Joker Offline
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RR Joker
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The Swamp
^^^this! The use of the term 'mortgage loan' leaves an awful lot of room for incorrect assumptions!
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#2044875 - 10/19/15 04:21 PM Re: Are the new TRID docs required for 2nd mtg loans? BYC Baird
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
Joined: Dec 2000
Posts: 21,293
It is a matter of learning how to read the rules.

1026.19(e) says:

"(i) Creditor. In a closed-end consumer credit transaction secured by real property, other than a reverse mortgage subject to § 1026.33, the creditor shall provide the consumer with good faith estimates of the disclosures in § 1026.37."

Lien position is not part of the requirement...therefore it covers all closed end consumer credit secured by real property.
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Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
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www.kaybeescomplianceinsights.com

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