The TRID Guidelines are often a big player when it comes to the life cycle of a mortgage loan. There are timing requirements to meet, disclosures to complete, and so much more. One of the main purposes of TRID is to get accurate “shopping disclosures” into an applicant’s hands quickly.
Listen as Jerod explains more about some of the timing requirements you need to be aware of during the shopping phase.
Transcript:
This is session two of the mortgage loan life cycle. We're going to pick up where we left off last week. On page 141, we're talking about the shopping disclosures phase of our mortgage loan life cycle. It is one of the larger chapters that we'll be covering. We're just about a third of the way through that here, maybe a little more than that. Page 141 is the loan estimate introduction. As far as the document goes, we're going to start with the delivery and timing of that loan estimate document. a1, small letter a, you've got to provide that loan estimate within three days of that sixth item for TRID. We talked about that back in session one. That's a milestone date that we need to make sure that we're documenting in our loan file documentation.
Now, there's another timeframe that goes along with this one. Letter b, there's a seven-day minimum timeframe that must be covered between when you deliver the loan estimate and when you can close that loan. My item with the letter b is going to be this. It's usually not a problem. But if you have lenders that dabble in TRID, so you got that lender that maybe mostly does commercial loans, but they're going to do a consumer loan to help out this or that borrower. And they take a piece of bare ground or a rental property or something, and they think they can close that right now. They can't because they have to satisfy this seven-day minimum.
Now, some of you're looking further on this page, and you're going, "Oh, there's a waiver for this that you can waive that seven-day requirement." Well, that waiver works much like some of the other delay timeframes that we're going to talk about in this mortgage life cycle about. For example, we will do the right of rescission later in the sessions. We'll also cover high-cost mortgage loans, and there's a timeframe tied to that requirement as well.
So yeah, these timeframes can be waived, but it's got to be a bonafide personal financial emergency. And that's going to be defined as the tornado just went through, the flood waters are coming, the furnace is out in the middle of the winter, funeral expenses, and things like that. And at the end of the day, the consumer has to put it in their own words. You can't have pre-printed forms to take care of this. They have to handwrite or type them up and submit them to you. And then you're going to be the one that makes the call. It's a judgment call as to whether or not it meets that bonafide personal financial emergency definition. Then, each delay timeframe has to be independently waived.
My recommendation is this. If you have someone that's trying to mess around with these delay timeframes, be it the one that's right in front of us here, the seven days, the right of rescission, or the high-cost mortgage loan. Get a compliance person involved, an expert involved, so that we make sure that the Is get dotted, and the Ts get crossed because there's a domino effect here of bad things that can occur as a result of a botched waiver in the truth in the lending environment.
Published
2022/01/10
