TRID: Construction Inspection & Handling Fees

 

Are you ready for the October 1st TRID changes? If you do construction loans, there are a number of changes.  The change that generated a lot of discussion in our recent TRID: All About Construction Loans webinar is disclosing inspection and handling fees, including draw fees. TRID 2.0 gives two options:

 

  • If you collect these fees at or before closing, disclose them on your Loan Estimate and Closing Disclosure.

 

  • If you collect these fees after closing, disclose them on an Addendum to the Loan Estimate and Closing Disclosure.

 

Treat any change like any other valid changed circumstance. Re-disclose within three business days of a valid changed circumstance to reset any tolerances.

 

Remember, disclose based on the best information available to you at that time. If you do so, you can go back to the borrower, even after closing, to collect a potential increase if the change is a result of a valid changed circumstance.

 

Check out our TRID: All About Construction Loans webinar to learn more about the upcoming construction loan changes in plain English!

 

Published
2018/09/14
Diane Dean

Diane Dean

Diane joined Banker’s Compliance Consulting with over 10 years of compliance experience and over 15 years of experience within the financial industry. Diane is a Certified Regulatory Compliance Manager (CRCM) and has a Bachelor’s Degree in Sociology with a concentration in Criminal Justice. She is a graduate of the Schools of Banking Compliance School and has participated in various other training opportunities throughout her career. Diane understands firsthand the struggles banks face in building and maintaining successful compliance programs. Her experience and common sense approach to consumer compliance is a great asset to our clients. Diane and her husband have two kids who keep them busy. She enjoys running and other sports and is a big Bugs Bunny fan! She’s a bit crazy in that she does enjoy reading some of these regulations and she’s a “crazy cat lady!” Her cat tales are hilarious!

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