Disclosure Timing

Compliance – Change of Circumstance – Fees Disclosure: What are the timing requirements if a CD has been issued and a valid change of circumstance occurs? In our case a POA was added, which resulted in an increase of recording fees.

Answer: It can be disclosed on the CD even if the initial CD has gone out. The fee can be increased as long as it is re-disclosed no later than 3 days after finding out about the POA. Your example does not reset the 3-day clock for closing. The APR is not increasing more than [...]

2019-02-21T16:13:23-05:00February 25th, 2019|

CFPB – TRID [TILA-RESPA Integrated Disclosure] FAQ Released January 25, 2019

Written By: Tammy Butler, Master CMB Hooray!  More clarity on TRID!  Anytime we don’t have to guess what to do regarding disclosures, is a happy day.  Read this quick FAQ to learn more. Rule Synopsis: On October 3, 2015 [yes, 3.5 years ago] TRID [TILA-RESPA Integrated Disclosure] changed the way that mortgage lenders disclose loans.  With [...]

2019-02-15T16:00:37-05:00February 10th, 2019|