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Cunningham & Company is a trade name for CMC Funding, Inc. NMLS ID#419981
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RESPA/TILA 2 The Consumer Financial Protection Bureau (CFPB) finalized amendments to Reg X and Reg Z to integrate the Truth in Lending (TILA) and Real Estate Settlement Procedures Act (RESPA) disclosures effective with loan applications dated October 3, 2015. The CFPB is now referring to the rule change as TRID (TILA-RESPA Integrated Disclosure.)
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RESPA/TILA RESPA/TILA TILA-RESPA Integrated Disclosure (TRID) Cunningham & Company is a trade name for CMC Funding, Inc. NMLS ID#419983 OVERVIEW: – Combines initial Truth-in-Lending disclosure (E TIL) and Good Faith Estimate (GFE) into one LOAN ESTIMATE (LE) disclosure – Combines final Truth-in-Lending disclosure and HUD-1 Settlement Statement into one CLOSING DISCLOSURE (CD) – Creates new timing requirements for receipt of CLOSING DISCLOSURE – Applications taken October 2, 2015 and before will continue with the current GFE, TIL, and HUD 1 Settlement Statement no matter the closing date.
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RESPA/TILA New Documentation Cunningham & Company is a trade name for CMC Funding, Inc. NMLS ID#419984
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LOAN ESTIMATE DISCLOSURE New Documentation Loan Estimate Page 1 The new Loan Estimate will make it easier for consumers to locate key information, including the interest rate, monthly payment, and cost to close the loan. Cunningham & Company is a trade name for CMC Funding, Inc. NMLS ID#41998 5
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LOAN ESTIMATE DISCLOSURE New Documentation Cunningham & Company is a trade name for CMC Funding, Inc. NMLS ID#41998 6
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LOAN ESTIMATE DISCLOSURE New Documentation Cunningham & Company is a trade name for CMC Funding, Inc. NMLS ID#41998 7 Loan Estimate Page 3 Total amount of interest the borrower will pay over the life of the loan, expressed as a percentage. Example: $100,000.00 Loan Amount $50,000.00 Interest TIP= 50%
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RESPA/TILA New Loan Closing Procedure Cunningham & Company is a trade name for CMC Funding, Inc. NMLS ID#419988
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CLOSING DISCLOSURE New Documentation Closing Disclosure Page 1 Page 1 of the Closing Disclosure mirrors page 1 of the Loan Estimate. Cunningham & Company is a trade name for CMC Funding, Inc. NMLS ID#41998 9
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CLOSING DISCLOSURE New Documentation Cunningham & Company is a trade name for CMC Funding, Inc. NMLS ID#41998 10 Closing Disclosure Page 2 Gone are uniform sections: No more 700-1400 series Fees and charges listed alphabetically under Loan costs Other costs Real Estate commission fees shown under H. Other Example: Real Estate Commission to ABC Broker CDE Broker Actual Fee shown in seller column
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CLOSING DISCLOSURE New Documentation Cunningham & Company is a trade name for CMC Funding, Inc. NMLS ID#41998 11 Closing Disclosure Page 3 Top portion compares Loan Estimate to Closing Disclosure costs Similar look to old HUD 1
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CLOSING DISCLOSURE New Documentation Cunningham & Company is a trade name for CMC Funding, Inc. NMLS ID#41998 12
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CLOSING DISCLOSURE New Documentation Cunningham & Company is a trade name for CMC Funding, Inc. NMLS ID#41998 13 Closing Disclosure Page 5 Contact information for all critical non-seller participating parties associated with the transaction to allow the consumer easier access to the information.
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NEW LOAN CLOSING PROCEDURE Preparation of Closing Disclosure Cunningham & Company is a trade name for CMC Funding, Inc. NMLS ID#41998 The Closing Disclosure integrates and replaces the Final Truth-in- Lending disclosure and the RESPA HUD-1 Settlement Statement. Three possible options: 1.Lender Preparation 2.Attorney Preparation 3.Dual effort between Lender and Attorney Who Prepares the Closing Disclosure? 14
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Consumer Receipt of Closing Disclosure Consumer must receive the Closing Disclosure no later than three precise business days before consummation. (Seller may receive Closing Disclosure at or before closing) NEW LOAN CLOSING PROCEDURE Consumer Receipt of Closing Disclosure Cunningham & Company is a trade name for CMC Funding, Inc. NMLS ID#4199815
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Sun.Mon.Tues.Wed.Thurs.Fri.Sat. 1234 567891011 12131415161718 19202122232425 262728293031 Consumer receives CD on Monday. Closing may occur on Thursday. Consumer receives CD on Thursday. Closing may occur on Monday Consumer receives CD on Monday (Tuesday is a Federal Holiday.) Closing may occur on Friday. NEW LOAN CLOSING PROCEDURE Consumer Receipt of Closing Disclosure Cunningham & Company is a trade name for CMC Funding, Inc. NMLS ID#41998 16
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Changes that would require a closing date to be rescheduled Disclosed APR is no longer within tolerance Loan product changes Prepayment penalty added NEW LOAN CLOSING PROCEDURE Closing dates Cunningham & Company is a trade name for CMC Funding, Inc. NMLS ID#4199817
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NEW LOAN CLOSING PROCEDURE Transition to new disclosures Cunningham & Company is a trade name for CMC Funding, Inc. NMLS ID#4199818
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Cunningham & Company is a trade name for CMC Funding, Inc. NMLS ID#4199819
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Cunningham & Company is a trade name for CMC Funding, Inc. NMLS ID#4199820
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