1. REVISED TRID KNOWLEDGE. CLARITY. RELIABILITY.
(888)

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

3. General TRID RULES

4. Scope
Closed-end
Consumer
Real Estate

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

6. Loan Estimate: Timing

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

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

9. 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

10. 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%

11. 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

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

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

14. Changed Circumstances
Extraordinary Event
Inaccurate Information
New information specific

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

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

17. 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

18. Record Retention
2 years
5 years

19. Loan Estimate

20. Loan Estimate: Page 1

21. Purpose
Purchase
Refinance
Construction
Home Equity

22. Loan Terms

23. Projected Payments

24. Payment Calculation

25. Payment Calculation: Adjustable Rate Interest Only Example

26. Projected Payments: Balloon Loan

27. Estimated Taxes, Insurance & Assessments

28. Costs at Closing

29. Optional Table for Transactions Without a Seller

30. Loan Costs: Origination Charges

31. Loan Costs: Services You Cannot Shop For

32. Loan Costs: Services You Can Shop For

33. Other Costs .

34. Cash to Close
else = $0

35. Adjustable Payment (AP) Table

36. Adjustable Interest Rate (AIR) Table

37. Additional Information

38. 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.

39. 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”

40. Confirmation Receipt

41. Closing Disclosure

42. Closing Disclosure

43. Projected Payments & Closing Costs

44. Loan Costs

45. Other Costs

46. Total Closing Costs

47. Calculating Cash to Close

48. Example of Tolerance Cure

49. Borrower’s Transaction

50. on Behalf of Borrower

51. Seller at Closing

52. Due from Seller at Closing

53. Calculation

54. Additional Information About This Loan

55. Escrow Details

56. No-Escrow Details

57. Loan Calculations

58. Additional Disclosures

59. Contact Information

60. Confirmation Receipt

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

62. 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

63. TRID FAQS 1-18
Pgs 31-36