Published
2018/05/04
Jerod Moyer
Hey, have you heard the news? The TRID black hole is about to close. Hi, this is Jared Moyer with bankers compliance consulting. On April 26th, the CFBB issued a final rule that is going to put to an end the question marks that surrounded being able to issue a revised closing disclosure and reset tolerances.
You see, the original rule that came out in December of 2015 left some question as to whether or not a revised closing disclosure issued in relation to a change circumstances that occurs after the the first closed disclosure was provided could reset tolerances. Now, this changed with the final rule that just came out comes as one very big caution, as you still can’t issue closing disclosures too early on in the process: in other words, you can’t just pencil whip them out the door so that you can satisfy the in-hand before three days element within the regulation. You’re not to issue the closing disclosure until you believe you have everything nailed down. This rule is going to provide some flexibility when we have changes that occur after you thought you had everything nailed down. They’re gonna make it real simple — essentially you’re gonna follow the other change circumstance rules and requirements that we already know from the loan estimate.
So it works like this: if you issued a closing disclosure because you thought everything was nailed down and then there’s this last-minute change, maybe the rate lock has to be extended because the borrower couldn’t close on time, and there’s a fee that you’re allowed to charge for that that. No longer be a zero percent tolerance that doesn’t allow you to to capture that fee. It’s simply going to work like this. When you learn that there’s this change within three days after learning of the change. So just like the loan estimate, you’ll have to issue that revised closing disclosure no more of the less for business less than four business days before closing nonsense that was there before with all the question marks and ambiguity that surrounded it.
So here’s what’s going on: we’re gonna be talking about this latest final rule as well as the July 2017 rules that came out that have the effective date of October 1st 2018. We’re going to be doing that on May 17th in a special two-hour webinar titled TRID – Just the New Stuff. We’re gonna be putting all that into plain English. Why? So that you can get back to doing what you do best. That’s serving your customers. We’ll hope to see you then. Thanks!