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Agenda TRID General Loan Estimate Closing Disclosure 2018 Changes Frequently Asked Questions

General TRID RULES

Scope Closed-end Consumer Real Estate

NoT Exempt Temporary Loans Loans over 25 acres Lot loans Construction loans Bridge Loans

Loan Estimate: Timing

Timing: The Closing Disclosure 3 Business Days Receipt Mailbox rule Business days Consummation

Timing Friday, June 5: Closing Disclosure is mailed Tuesday, June 9: Consumer Receives Closing Disclosure Friday, June 12: Consummation

Timing Mon: 6/1 Application submitted Tues: 6/2 Loan Estimate Mailed Fri: 6/5 Loan Estimate received and consumer gives intent to proceed Wed: 6/10 Consumer locks rate Mon: 6/15 Revised Loan Estimate mailed to consumer 6/18 Revised Loan Estimate received by consumer

Timing Tues: 6/16 Because of a COC, title insurance increases, but only 6% over amount disclosed – no LE required Fri: 6/19 Pest inspection shows termite damage requiring an additional inspection bringing totaling 5% of originally disclosed Mon: 6/22 Revised Loan estimate mailed because combined change is now over 10%

Sat: 6/27 COC increase title fees once again Timing Friday: 6/26 Closing Disclosure hand delivered to consumer – earliest closing date is 6/29 Sat: 6/27 COC increase title fees once again Tues: 6/30 Closing Disclosure showing updated fees hand delivered, closing can still happen today

Timing? June 4: Change of Circumstance June 5: CD Scheduled to be Mailed June 9: Consumer Receives CD June, 12: Scheduled Closing Date

Revised Loan Estimates Change in Circumstance Fee exceeds tolerance 3 business days Before closing disclosure

Changed Circumstances Extraordinary Event Inaccurate Information New information specific

Revised Closing Disclosures Any change Post-Closing Non-numerical clerical error Tolerance Cure

Revised Disclosure: Waiting Period APR out of tolerance product changes Add a prepayment penalty

Tolerance Items 0% 10% Unlimited Originator Charges Choose off the list or wasn’t on the list Items the borrower can shop for and choose someone not on the list Cannot Shop For Recording Fees Items that aren’t required by the creditor – not a tolerance item at all Transfer Taxes Section B – did not shop + Section E Escrow payments, Insurance premiums, etc., - not tolerance items at all Sections A, B and E Bucket Section C and H Line x Line   Items compared as a whole group – 10% items in Section B + Section E

Record Retention 2 years 5 years

Loan Estimate

Loan Estimate: Page 1

Purpose Purchase Refinance Construction Home Equity

Loan Terms

Projected Payments

Payment Calculation

Payment Calculation: Adjustable Rate Interest Only Example

Projected Payments: Balloon Loan

Estimated Taxes, Insurance & Assessments

Costs at Closing

Optional Table for Transactions Without a Seller

Loan Costs: Origination Charges

Loan Costs: Services You Cannot Shop For

Loan Costs: Services You Can Shop For

Other Costs .

Cash to Close else = $0

Adjustable Payment (AP) Table

Adjustable Interest Rate (AIR) Table

Additional Information

Comparisons Must calculate total payments and principal paid off in the first five years First time we see APR Truncate to at most 3 decimals If APR is a whole number, stop at decimal If less than 3 decimals, truncate extra “0s,” for example, an APR of 5.250% should be listed as 5.25% TIP = Total scheduled interest of term of loan divided by loan amount – Includes prepaid interest the consumer will pay.

Other Considerations   For disclosures of permanent loans issued before construction, include the statement: “You may receive a revised Loan Estimate at any time prior to 60 days before consummation”

Confirmation Receipt

Closing Disclosure

Closing Disclosure

Projected Payments & Closing Costs

Loan Costs

Other Costs

Total Closing Costs

Calculating Cash to Close

Example of Tolerance Cure

Borrower’s Transaction

on Behalf of Borrower

Seller at Closing

Due from Seller at Closing

Calculation

Additional Information About This Loan

Escrow Details

No-Escrow Details

Loan Calculations

Additional Disclosures

Contact Information

Confirmation Receipt

Revisions, Revisions, Revisions October 3, 2015 October 1, 2018 June 1, 2018

Changes Overview Compliance Dates Coverage Total of Payment Tolerances Revised Disclosures and Good Faith Partial Payment Disclosures Escrow Closing Notice Construction Loans Simultaneous Seconds Rounding Calculating Cash to Close Loan Estimate Disclosures Closing Disclosure Disclosures

TRID FAQS 1-18 Pgs 31-36