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TRID for Construction Loans - Updated
Presented by Jack Holzknecht and Kelly Owsley
June 22, 2016
Construction loans are significantly impacted by the TRID rules. Many construction loans were exempt from the old disclosure requirements; however, these loans are clearly covered by the new rules. Many lenders are still scrambling trying to master the details of the new integrated disclosures. Construction loans are causing problems because of a lack of binding clarification of the requirements.
The CFPB provided few details regarding completion of the Loan Estimate and the Closing Disclosures for these loans. The regulation does not contain sample forms for construction loans. The Commentary only mentions construction loans a few times and those references provide little guidance for completing the forms.
Creditors continue to report problems producing construction loan disclosures using loan origination software (LOS) products. Apparently some LOS products cannot produce construction disclosures while others produce the disclosures for some construction loan options, but not for others.
Lenders need solutions. Without details, how do you complete disclosures, or check disclosures produced by your LOS? Without details, how do you determine what construction loan options to offer to your customers? It does not appear likely that the CFPB will provide binding guidance in the near future.
The 2015 TRID for Construction Loans webinar conducted in October 2015 has been updated to include, among other new information, informal guidance provided by the CFPB in its March 2016 webinar on the same topic.
This program is designed to fill the void created by the lack of regulatory guidance for construction loans. It explains coverage and exemption rules. It provides section-by-section guidance on completing the Loan Estimate and the Closing Disclosure for the common construction loan options. It answers the many questions you have regarding the proper disclosure of construction loans.
This program will cover:
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