TILA-RESPA (TRID) Rule

TILA-RESPA (TRID) Rule

1. Established October 3, 2015

   • Before and TIL disclosure and the Good Faith Estimate was required
     • Now the Loan Estimate combined both disclosures into one
       • Must be delivered 3 business days after lender recieves application and no later then 7 days prior to consummation
         • Creditor can not collect any fees for loan processesing until applicant shows intent to proceed.
           • Loan estimate is comprised of Date Issued, Sale Price, Purpose, Product, and Loan Type
       • The aggregate amount of closing costs and recording fees does not exced the amounts disclosed on the loan estimate by more then 10%
         • The fees for third-party services are not paid to the creditor or an affiliate of the creditor
           • The creditor permits the consumer to shop for settlement services
           • For third party services there is a zero tolerance for varience between the estimate and actual charge
       • Revised Loan Estimate is premitted
         • Chaged Circumstances(ex. aggregate amount of estimated charges to increase by more then 10%)
           • Change in Eligibility
             • Consumer requested revisions
               • Delays caused by the consumer
                 • The applicant waits more then 10 days to proceed with the Loan application
                 • Delays related to construction loans
                   • If the creditor reasonably expects settlement to be more than 60 days after providing loan estimate
         • Disclosure must be provided within 3 business days of change and not later than 4 business days before consummation

2. Similiarly there was the TIL and Closing and HUD1 settlement statement, the closing disclosure combines both

   • Estimated Closing Cost
     • Loan Cost
       • Origination Charges, Services you cannot shop for, services you can shop for, total loan cost
         • Other Cost
           • Taxes and other government fees, prepaids, initial escrow payment at closing, other, total other costs, total closing cost
     • Estimated Cost to Close
       • Total closing costs, closing costs financed, down payment/funds from borrower, deposit, funds for borrower, seller credits, adjustments and other credits, and estimated cash to close
     • Must be recieved no later then 3 business days prior to consummation
       • Consumers may wait and aditional 3 business days if there is a change in APR, Loan Product, or addition of a prepayment penalty
         • Any refunds of excess must be paid within 60 days of comsummation

3. Does not apply to reverse mortgages, HELOCS's, and mortgage's secured by a mobile home