Tagged: TRID, TRID COMPLIANCE, TRID LOAN
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What is TRID RULE? How Does TRID WORK in Mortgages
Posted by Chase on August 7, 2024 at 7:13 pmWhat is the purpose of TRID? What is TRID in the Mortgage Loan Process? What Are The Requirements of a TRID Loan? What Are The 6 TRID REQUIREMENTS? WHAT ARE THE RULES FOR TRID COMPLIANCE?
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What is TRID?
TRID stands for TILA-RESPA Integrated Disclosure. It was created to simplify the mortgage loan process by combining the disclosures required under the Real Estate Settlement Procedures Act (RESPA) and the Truth in Lending Act (TILA). The objectives of TRID are:
Greater Transparency: Offer borrowers clearer and more concise information about their mortgage costs and terms.
No Surprises: Help borrowers avoid unexpected expenses at closing time.
Streamlined Disclosures: Merge multiple forms into simpler, more user-friendly documents.
Consumer Protection: Give consumers enough data to make informed decisions about their mortgage loans.
TRID in the Mortgage Loan Process:
Two main forms are required under TRID regulations:
Loan Estimate (LE): This document outlines an estimate of loan terms and closing costs. It must be given to a borrower within three business days after receiving a loan application.
Closing Disclosure (CD): This form shows final mortgage terms and costs. It must be given to a borrower at least three business days before closing a loan.
Requirements of a TRID Loan:
These are key requirements that all TRID loans should meet:
Delivery Timeframes for Disclosures: Within three business days of receiving an application for credit secured by real property, lenders must provide applicants with good faith estimates of credit costs and transaction terms on Loan Estimates.
Accurate Information:
- The information on Loan Estimates must be accurate and reflect all material terms.
- This includes interest rates or payment changes due to adjustable-rate features.
- Fees charged during closing include points or origination fees.
- Charges are imposed solely because credit was extended below par value or rebated upon full prepayment within three years from the consummation date.
- This excludes the amounts paid to persons other than creditors.
- It also excludes affiliates who do not regularly participate significantly in residential mortgage transactions involving extensions above par value.
Good Faith Estimate: The Loan Estimate should indicate costs and fees in good faith, meaning they must be close to the final amounts shown on a Closing Disclosure.
Delivery of Closing Disclosure:
- Creditors must provide borrowers with copies of all corrected closing disclosures at least three business days before the scheduled closing date.
- The closing disclosures need to reflect any changes made after consummation.
- The disclosures required under §1026.19(f)(2)(iii) are provided to such consumers.
- If revised estimates are provided under it irrespective of whether an event requiring redisclosure has occurred before it, but not later than one business day before consummation if changed circumstances result in a revised APR or other change requiring delivery under §1026.19(f)(2)(ii).
Handling Changes: If loan terms or costs significantly change, revised Loan Estimates and Closing Disclosures need to be provided depending on when the change occurs, and enough time must be given for borrowers to review these changes.
The 6 TRID Requirements: A complete application consists of six pieces of information:
- Borrower’s Name.
- Borrower’s Income.
- Social Security Number (to obtain a credit report).
- Property Address.
- Estimated Value of Property.
Amount of Loan Sought
Once the lender has received these six pieces, it is considered that they have everything necessary to issue a loan estimate within three business days.
Rules for TRID Compliance:
To be compliant with TRID rules and regulations, lenders need to follow these rules:
Deliver Disclosures Timely: Provide the borrower with both Loan Estimates and Closing Disclosures within their respective time frames.
Good Faith Estimate Requirements: Expenses and fees disclosed must be done in good faith, meaning they reflect actual costs incurred by lenders, except where otherwise exempted from this requirement under Regulation Z section 1030.2(a)(3).
Tolerance Levels: There are certain limits allowed for changes between what was disclosed in the Loan Estimate versus what appears on the Closing Disclosure:
Zero Tolerance: Certain charges, such as the Lender’s Lender’s transfer taxes, cannot be increased.
10% Tolerance: Some fees may change, but the total cost cannot increase more than 10 percent (e.g., Recording fees or third-party services).
No Tolerance: A few charges can change without limit (e.g., prepaid interest, property insurance premiums).
Revised Disclosures: If a significant change occurs, an updated Loan Estimate or Closing Disclosure must be provided enough time for borrowers to review it.
Record Keeping: All Loan Estimates should be kept on file for at least three years, and a Closing Disclosure for 5.
Compliance with Timing Requirements: To avoid delaying the closing process, timing requirements must be met for disclosures, redisclosures, and disclosures.
Understanding and adhering to TRID requirements in mortgage loans is important to promoting redisclosures, protection, and transactional ease.
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TRID stands for TILA-RESPA Integrated Disclosure. It streamlined the mortgage loan process by combining the disclosures required under the Truth in Lending Act (TILA) and Real Estate Settlement Procedures Act (RESPA) into one. The main aims of TRID include:
More Transparency: Making sure that borrowers are provided with clearer, more concise information about their mortgage terms and costs.
Avoiding Surprises: Helping borrowers avoid being hit with unexpected expenses at closing time.
Simplifying Disclosures: This involves consolidating multiple forms into fewer, simpler documents.
Consumer Protection: Ensuring that consumers have enough details to make informed decisions when it comes to taking out a mortgage loan.
TRID in Mortgage Loan Process
TRID Stands for? What does TRID do?
The two primary forms used by TRID regulations are as follows:
Loan Estimate (LE): A document which provides an estimate of loan terms and closing costs. It should be given to the borrower within three business days after receiving an application for a loan.
Closing Disclosure (CD): This form sets forth final terms and costs of the mortgage. It must be provided to the consumer at least three business days prior to consummation or closing of transaction.
Requirements of a TRID Loan
Requirements for a TRID Loan – How Do They Work?
TRID loans come with certain obligations that must be met, such as:
Timely Disclosure Delivery(s): Lenders must deliver Loan Estimate within three business days after receiving complete application; also, accurate reflection of disclosed data is required on Closing Disclosure.
Good Faith Estimate(s): Costs on LE should be made in good faith and reasonably close to actual amounts listed on CD (Closing Disclosure).
Delivery of Closing Disclosure Form(s): The creditor is responsible for ensuring that this form reaches its destination not later than 3 calendar days before consummation or closing takes place.
Handling Changes: Significant changes to loan terms or costs must result in revised Loan Estimate or Closing Disclosure being provided, depending on change made and time frame involved, if any.
The 6 TRID Requirements
What are the six pieces of information that define a complete TRID application?
Six pieces of information which constitute a complete TRID Application are:
Name(s) of Borrower(s)
Income of Borrower(s)
Social Security Number (for credit report)
Address of Property Being Financed
Estimated Value Of The Property
Amount Of Loan Sought
Once these 6 items have been received by lender; they have what is called a complete application and must issue LE within three business days.
Rules for TRID Compliance
How Do You Comply with the Rules?
In order to be compliant with TRID, lenders need to follow certain guidelines:
Timely Issuance of Disclosures: Deliver LE & CD within prescribed time frames.
Good Faith Estimate Requirements: Costs and fees disclosed should be made in good faith and consistent with actual figures.
Tolerance Levels: There are different tolerance levels for changes in costs between Loan Estimates and Closing Disclosures:
Zero Tolerance – No increase allowed for certain fees like lender fees or transfer taxes.
10% Tolerance – Some fees may change but total can’t increase more than 10% (e.g., recording fee, third party service).
No Tolerance – Certain fees can change without limit (e.g., prepaid interest, property insurance premium).
Revised Disclosures: Revised LEs/CDs must be issued when there is a significant change; borrowers should be given sufficient time to review such changes.
Record Maintenance: Keep record of every handout given to lendees, loan estimate for 3 years and closing disclosure for 5 years.
Time Requirement Adherence: Follow rules about when disclosures should be made or remade, otherwise it may cause delays in the closing process.
The knowledge about TRID is vital because it helps in creating trust between the mortgage borrowers and lenders hence facilitating easy lending transaction processing.
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- This reply was modified 3 months, 2 weeks ago by Gustan.