TRID TIP OF The Week

Posted by Krista Sabol on Feb 17, 2015 in Regulations, RESPA, TILA, TRID Explaining Total Interest Percentage (TIP) Originators and closers will be faced with a new acronym on the Loan Estimate(LE) and Closing Disclosure (CD). They will need to explain the Total Interest Percentage or TIP to the borrower. The TIP is the total amount of interest the borrower will pay over the loan term as a percentage of the loan amount. The TIP is shown along with the APR, Finance...
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Integrated Disclosure ‘Business Purpose’ Nightmare

Posted by Krista Sabol on Feb 8, 2015 in Compliance, Regulations, RESPA, TILA To disclose or not to disclose, that is the question for non-owner occupied residential loans under the integrated disclosure rule. TILA and RESPA have long stated that disclosures under their rules do not apply to a business purpose loan. Technically a loan used to purchase or refinance a rental property today does not need a GFE or TIL. But as an industry, we like standard procedures that are...
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TRID in the Weeds

Posted by Krista Sabol on Jan 23, 2015 in Compliance, IMU Blog, News, Regulations, RESPA, Rules Watch, TILA by Alice Alvey for Mortgage Compliance Magazine As we step into 2015, mortgage lenders, brokers, depositories, and vendors are at various stages of understanding and preparing for the TILA-RESPA Integrated Disclosure (TRID) rule (Rule). In an informal survey of various audiences over the last few weeks, it seems that roughly 60% are beyond the initial discovery phase and are actively...
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Home Warranty Companies and Section 8 Violations

Posted by Krista Sabol on Jun 29, 2010 in RESPA Section 8 HUD issues Final Rule RE: Home Warranty Companies and Section 8 Violations On June 25, 2010, HUD issued a final rule addressing whether compensation paid by Home Warranty Companies to real estate and mortgage brokers violates Section 8 (the “anti-kickback” section) of RESPA. The rule is effective on the date it was published (June 25), but HUD is accepting public comments until July 26,...
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FHA Minimum Investment

Posted by Krista Sabol on Mar 15, 2010 in FHA, FHA/VA, RESPA, RESPA 2010 Every day it seems someone finds a loophole that has to be closed or confirmed and today is no exception. In the new world of RESPA and tolerance requirements a lender may be faced with providing a refund of closing costs to the borrower at the time of closing if the fees were under stated by more than 10%. The consequence may lead to the borrower receiving cash back at closing and/or appearing...
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RESPA & Origination: Complaining won’t help

Posted by Krista Sabol on Mar 15, 2010 in Origination, RESPA 2010 I received an email today from a loan originator complaining about the new GFE as if it had just been rolled out in March! The ranting consisted of the usual complaints with the form – ‘why doesn’t it show the seller credit?!’… ‘this is not clearly showing the funds needed to close’… ‘why do I have to show block 1 so large in order to get block A to reflect the right...
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State and Local Taxes

Posted by Krista Sabol on Mar 15, 2010 in RESPA, RESPA 2010 The transfer tax debacle continues as we all struggle to stay competitive and in compliance with block 8 of the new GFE. With potentially thousands of dollars at risk, many lenders have chosen a very conservative route and require disclosure of all state and local taxes in block 8, regardless of whether state law dictates the seller must pay the fee. There is certainly room in the RESPA...
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Excess Credits and RESPA

Posted by Krista Sabol on Mar 15, 2010 in RESPA 2010 Our client initially thought they had to disclose YSP on loans that they funded with their own money and they put it on the GFE which was issued after 1/1/2010. In order to give themselves extra room on the GFE they cushioned not only their estimated fees that go into block one but they added cushion to third party costs like title, etc. They were doing a no cost loan for the borrower so they...
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