Market Update: Mortgage Disclosure Improvement Act (MDIA) Truth in Lending (TIL) Changes

Outline Purpose of the Mortgage Disclosure Improvement Act (MDIA) Key Provisions Impact of Each Provision The Mortgage Process and Timelines: How the MDIA Affects You and Your Customers When your customer applies for a loan Waiting period before closing Waiting period in the event of re-disclosure Timeline examples Why the APR May Change Things to Consider—3/7/3 Summary Our Commitment

Purpose of the MDIA The Mortgage Disclosure Improvement Act (MDIA) is intended to protect consumers and make it easier for them to understand Truth in Lending (TIL) rules. All lenders must adhere to these guidelines or face stiff penalties The rules go into effect for mortgage applications taken as of July 30, 2009 Coldwell Banker Home Loans is committed to full compliance with these regulations

Key Provisions The MDIA rules describe: Fees that can be collected before a lender provides an initial TIL disclosure When the lender must deliver TIL disclosures Waiting periods that must occur before closing The purpose of each waiting period is to give customers more time to fully review and understand the loan disclosures NOTE: There is an additional waiting period if the Annual Percentage Rate (APR) was understated by more than 0.125% in the TIL disclosure

Impact of Each Provision Key Provisions Impact on Coldwell Banker Home Loans Process The lender must provide or mail an initial TIL disclosure within 3 days after receiving the customer’s application.1 No change. Coldwell Banker Home Loans typically mails all required documents to customers within 24 hours. The lender must deliver or mail a TIL disclosure at least 7 business days before closing.2 The earliest possible closing date is 7 business days after the lender issues the initial TIL disclosure. A final, accurate TIL must always be provided at closing. If the annual percentage rate (APR) increases more than 0.125%, the borrower must receive a revised TIL at least 3 business days before closing. Closing may be delayed due to this additional 3-day waiting period, however, Coldwell Banker Home Loans has a process in place to minimize the chance that this will occur. 1. Assumes the customer has signed a contract to buy and provided a property address. This does not apply to investment properties. 2. Business days includes Saturdays, but not Sundays or legal holidays.

The Mortgage Process and Timelines When your customer applies for a loan: The lender must provide (or place in the mail) an initial Truth in Lending (TIL) disclosure within 3 days after receiving the customer’s application This applies if the customer has signed a contract to buy and has provided the lender with a property address This does not apply to investment properties Coldwell Banker Home Loans can help you and your customers save time. Our platform prints and sends a TIL disclosure and loan documents promptly.

The Mortgage Process (cont’d) When your customer applies for a loan (cont’d): Other than a credit report fee, the lender is not permitted to collect any fees before the customer receives the TIL (or 3 business days after the lender mails it) We collect the customer’s credit card information at application, however, no charges will be applied unless the application is canceled* *If the loan is canceled for any reason, we reserve the right to charge a fee as permitted by state law.

The Mortgage Process (cont’d) There is a waiting period before closing: The earliest that a borrower can close is 7 days after the initial TIL was placed in the mail or provided to the borrower The lender must deliver (or place in the mail) a TIL at least 7 business days before closing* A final, accurate TIL must always be provided at closing Closing may be delayed if the APR changes by more than 0.125% (see next slide) *Business days include Saturdays, but not Sundays or legal holidays

The Mortgage Process (cont’d) There is an additional waiting period before closing in the event of re-disclosure. For example: The APR provided in the initial TIL was understated by more the 0.125%* The customer must receive a revised TIL at least 3 business days before closing *For example, this could occur if the customer floats their interest rate and then locks in at a higher rate than disclosed in the initial TIL.

Example #1: APR does not increase by more than 0.125% Timeline Examples Example #1: APR does not increase by more than 0.125% Monday, August 3 Application taken (A) Tuesday, August 4 Initial TIL goes in the mail (B) Wednesday, August 12 Earliest possible day that closing can occur (C)* A B C *Business days include Saturdays, but not Sundays or legal holidays

Timeline Examples (cont’d) Example #2: APR increases by more than 0.125% Monday, August 3 Application taken (A) Tuesday, August 4 Initial TIL goes in the mail; customer does not to lock rate (B) Monday, August 10 Customer locks rate; APR increases by more than 0.125%; revised TIL required (C); revised TIL sent to customer (C) Thursday, August 13 Lender can assume that customer has received new TIL (D) Monday, August 17 Earliest possible closing day (E)* A B C D E *Business days include Saturdays, but not Sundays or legal holidays

Why the APR May Change There are a number of reasons why the APR may increase by more than 0.125%: Changes in interest rates An increase in the loan amount A change in the type of loan An increase in fees charged A change in the loan-to-value

Things to Consider: 3/7/3 3/7/3 summary: 3 business days after receiving the customer’s application, the lender must provide an initial TIL 7 business days after the lender delivers/mails the initial TIL = the earliest possible closing date 3 business day additional waiting period prior to closing—ONLY IF the APR increases by more than 0.125%, requiring a revised TIL for customer review When writing a purchase contract, remember that the earliest possible day that closing can occur is 7 business days after the initial TIL is issued Set your customers’ expectations about closing timelines and plan for a closing date that provides enough time to accommodate the additional waiting period required if the APR increases by more than 0.125%

Our Commitment We are a lender you can trust. We are committed to regulatory compliance and ethical lending standards—and to managing these changes while providing you and your customers with excellent service. We make it a priority to do the right thing for you and your customers When you recommend us, we’ll give your customers a reliable, same-day pre-approval decision and tell them exactly what they need to do to get to closing We work hard to help your customers find the mortgage that’s right for them Ask your customers to contact me for a free same-day loan decision. Coldwell Banker Home Loans, 1 Mortgage Way, 3rd Floor, Mt. Laurel, NJ 08054. Alaska Licensed Mortgage Lender #100184, 866-462-8266; Arizona Residential Mortgage Licensee #BK 0907285; Licensed by the Department of Corporations under the California Residential Mortgage Lending Act; Georgia Residential Mortgage Licensee #20292; Illinois Residential Mortgage Licensee #MB.6759857; 122 S. Michigan Avenue, Suite 1900, Chicago, IL 60603, 312-793-3000; Massachusetts Licensed Mortgage Lender and Mortgage Broker #MC 4134; Minnesota - This is not an offer to enter an interest rate lock-in agreement; Licensed by the New Jersey Department of Banking and Insurance; Licensed Mortgage Banker - NYS Banking Department; Licensed by the New Hampshire Banking Department; Licensed First Mortgage Banker by Pennsylvania Department of Banking; Rhode Island Licensed Lender; Licensed by the Virginia State Corporation Commission, Lic. No. MC-3695. In Massachusetts, mortgage financing provided by Coldwell Banker Home Loans LLC. Coldwell Banker® and the Coldwell Banker Logo are registered trademarks licensed to Coldwell Banker Real Estate LLC and used with permission. Equal Housing Lender. 057S8583-07-09