HUD1 and GFE post-TRID

Hi gang, I have a question and I need your help!

I know this may be a silly question, but I just started in compliance last month (Very Excited! )

My question is:

What loans or types of loans do the HUD-1 and GFE still apply to? I understand that TRID/TILA (Reg Z) covers most scenarios, but I can't seem to determine what is still covered solely by RESPA.

Loans to an organization for consumer purposes
Loans secured by Co-ops
Reverse mortgages

Reverse mortgages still play by the old rules -- they are subject to RESPA and you have to use a GFE and HUD-1 and because they are also subject to Reg Z, you have to provide disclosures under the old rules.

Technically (and I know this statement will draw arguments to the contrary), a loan that is to an entity but for a consumer purpose can be subject to RESPA and not to TILA. An example could be a loan to an LLC with the loan purpose of purchasing a residence for the owners of the LLC. Assuming that the law allows the LLC to engage in such a transaction, it would be exempt from Reg Z even if the individuals guarantee the loan, because the borrower is an entity. Since the exemption in Regulation X for business-purpose transactions is based on loan purpose and not on who or what the borrower is, the loan would still be subject to RESPA.

John: FWIW, I agree with you 100%.

The real world problem is finding a system to kick out RESPA disclosures for these rare loans.

Start by finding a typewriter.
>>>>A what?
A typewriter?
>>>>What's a typewriter?
Never mind.

We do Oh, and applications secured by co-ops until 10/01/2018, when those then fall under TRID.

Unless in your state a coop is considered real estate. Pulling them in under the TRID rules nationwide was one of the smarter moves in the amendments. And I believe you will be able to treat them as TRID-worthy starting 10/10/17 if you want to get started.

Thank you gentlemen for your clear and succinct responses! Your expertise is appreciated!

Welcome to BOL's Discussion Forums, Rookie. And congratulations on your new compliance assignment. We wish you a fast learning curve, perseverance, the ability to figure out where things are (and a long memory to go with it), and, above all, management support of your efforts.