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.
Be sure to JOIN US for our five-part webinar series, “Mortgage Life Cycle”.
Listen as Jerod explains more about some of the timing requirements you need to be aware of during the shopping phase.
*Includes a 900+ page resource manual!
Designed for consumer real estate loan officers, loan processors, compliance, and audit personnel.
(12.5 Continuing Education credit hours)
PRESENTERS LIVE ON VIDEO!
NO CHARGE FOR ADDITIONAL LOCATIONS!
Published
2022/01/28
This is session two of the mortgage loan life cycle. We’re going to pick up where we’ve 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 certain that we’re documenting in our loan file documentation.
There’s another timeframe that goes along with this one. Letter b, there’s a seven-day minimum timeframe that has to be covered between when you deliver the loan estimate and when you can actually close that loan. My item with letter b is going to be this. It’s usually not a problem. But if you have lenders that dabble in TRID, you got that lender that may mostly do 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 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.
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, in this mortgage life cycle, about. For example, we’re going to do the right of rescission later on 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 floodwaters are coming, the furnace is out in the middle of the winter, funeral expenses, 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 got to handwrite them 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. And then each delay timeframe has to be independently waived.
My recommendation is this. If you have someone 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, to make sure that the Is gets 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.