Ark-La-Tex Financial Services, LLC - For internal use only 1

TILA – RESPA Integrated Disclosures (TRID)

Townhall WebinarProcess and Tolerances

03/2015

03/2015 Ark-La-Tex Financial Services, LLC - For internal use only 2

Benchmark Process – Delivery of Closing Disclosure (03/14/2015)

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Loan clear to close

Pre-draw process (including

Compliance Analyzer) /

Prepare Closing Disclosure

Provide figures for pages 2 and 3 of

Closing Disclosure

Send Closing Disclosure to

consumer

Cc: loan originator, processor and settlement agent

Electronic signature and return signed

Closing Disclosure

Prepare closing documents

3-Business Day Waiting Period

(Business day is Monday – Saturday,

excluding federal holidays)

Loan closing· Signing of documents· Obtain authorization

for settlement· Disburse funds

Prepare seller’s Closing Disclosure

Deliver to settlement agent

Confirm receipt to start 3-business

day waiting period

Confirm final title/escrow fees,

prorated taxes, HOA fees, and other fees and

chargesProcess

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Closing Disclosure – Page 2

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Closing Disclosure – Page 3

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ALTA Closing Disclosure Calendar

03/2015

Good Faith Estimate Tolerances (Today)

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Loan Estimate Variances (August 1)

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These charges cannot increase at settlement:

[Zero Tolerance]

• Origination charges, including points and other fees paid to lender or broker (Section A)

• Services paid to affiliate of lender to broker (all Sections)

• Services borrower did not shop for, such as appraisal and credit report (Section B)

• Transfer taxes (Section E.02)

The total of these charges can increase up to 10% at settlement:

[10% Tolerance]

• Services the borrower did shop for if both of the following apply (Section C):• Paid to unaffiliated third party• Consumer either selects provider

on Settlement Service Providers List or does not select any provider

• Recording fees (Section E.01)

These charges can change at settlement:

[No Tolerance Limitation]

• Prepaid interest (Section F)• Homeowners' insurance premium

(Section F)• Initial escrow payment at closing

(Section G)• Required services that you can shop

for - if borrower selects an unaffiliated third party provider not on the Settlement Services providers List (Section C.)

• Charges paid to third party provider for service not required by creditor, such as home warranty fee, HOA fees (Section H)

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Loan Estimate and Closing Disclosure

03/2015* Unless affiliated with creditor or broker, then zero tolerance

Settlement Service Providers List

Ark-La-Tex Financial Services, LLC - For internal use only 903/2015

Settlement Service Providers List

• If consumer is permitted to shop, we must provide written list of providers to the consumer

• Must list at least one available settlement service provider for each service

• Providers must correspond to the Loan Estimate, Section C.

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Resetting the 10% tolerance

• Example• Initial Loan Estimate estimates $400 in the

10% bucket• Changed circumstance increases fees by

$20 (5%)• Tolerance is not reset and revised Loan

Estimate is not required• Another changed circumstance increases

fees by $28 (7%)• Combined with earlier change of

circumstance fees increased $48 (12%)• Revised Loan Estimate provided with new

fees of $448 within three business days• Tolerance reset: Fees can increase by

another 10% ($44) before closing

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• You have to cross the threshold:• 10% tolerance is not reset if

changed circumstance increases aggregate total of charges by 10% or less

• You may reissue Loan Estimate but it must be disregarded when testing for compliance with tolerances

• Three-day requirement for reissuing Loan Estimate measured from the event that causes the aggregate increase to exceed 10%

What to do now

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• Talk to your real estate agents and settlement agents

• Flyers in Marketing Machine• More to come

• Tools on Benchmark Portal• ALTA Closing Disclosure Calendar• TIP Explanation• Presentations

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THANK YOU

03/2015