Under the TRID rules, a lender may increase a fee once disclosed as being non-shoppable by the consumer when the result of an event or circumstance taking place after a disclosure is issued. These are known under the law as “allowable changes in circumstances.” In such justifiable situations, a fee which is directly related to the change may be increased.…
The other day, I wrote about the TRID panel I moderated at our recent inaugural LoanLogics’ User’s Conference at the Sawgrass Marriott in Florida. During that presentation, Noerena Limon, Quality Analyst with the CFPB, mentioned, on more than one occasion, the importance of consumer education and what CFPB expects from a lender and is doing to help. I mentioned that…
It may not be good grammar but it makes the point. When I travel, I often wonder who gets the flights that depart from gates 1, 2 or 3 at the airport. For some reason, it seems I always end up leaving from a gate at the very end of the terminal. Ironically, when returning from our recent LoanLogics Users…
Better late than never. The VA has issued their guidance for the disclosure of allowable fees to veterans for a VA guaranteed loan. VA Circular 26-16-11 (Exhibit A & Exhibit B) outlines how a lender should be disclosing allowable fees and charges and how a lender and seller credit should be reflected on the new Closing Disclosure to offset an…
Maybe secondary market investors and correspondent lenders can take a page out of Fannie’s and Freddie’s rep and warrants book. These agencies are not delaying the purchase, holding up funding or denying the purchase of loans originated and closed under the new TRID rules. They buy the loans originated by lenders for sale and delivery to them; either whole loan…
According to Fitch Rating, investors may be a little too picky when it comes to denying loan purchases because of a TRID document not being prepared exactly per the new rules (TRIDSlips). The amount of data required to appear on each new disclosure, coupled with the requirements for how it should be reported, creates some major challenges for a lender.…
