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Closing Disclosures under TRID 2.0 - 2018
John Burnett Recorded on August 16, 2018
The Bureau's 2017 revision of the Regulation Z TRID rules resolved a lot of problems that lenders were having providing Loan Estimates and Closing Disclosures that conformed to the rules. The changes were effective on October 10, 2017, but compliance isn't mandatory until October 1, 2018. Have the changes been made in your institution's loan origination software and procedures? Or are you (or your vendor) holding out to the last minute? That compliance deadline is fast approaching, and you need to be ready.
The updates are as beneficial to lenders as they are to consumers. They clear up major questions about disclosing construction loans, provide more flexibility in the Cash to Close table, and address a lot of other challenges lenders experienced under the old requirements.
The Bureau has also made changes effective June 1, 2018, that affect the use of revised Loan Estimates, or a Closing Disclosure (initial or revised) to disclose certain closing costs changes occurring at or around the time for Closing Disclosures.
In this webinar, John will focus on completion of the Closing Disclosure. He'll review the basics on timing requirements and other unchanged parts of the Closing Disclosure requirements, and focus on changes that clarify rules on providing revised or updated "CloDs."
The Bureau's considerable updates to Appendix D and the disclosure of construction loans and their impact on the Closing Disclosure will also be discussed.
The addition of coverage for cooperative units
Proper completion of the property value
Disclosing the loan term for a construction loan
Clarifying the Loan Purpose disclosure
Which rate and payment amount to disclose for an ARM
Completion of the Estimated Taxes, Insurance & Assessments escrow response
Simultaneous subordinate financing
Disclosing construction loan inspection and handling fees
Changes in the math instructions for the Calculating Cash to Close table
Disclosing seller credits
The risks in disclosing lender credits
Calculating the Total of Payments
The new, more sensible, rules on rounding and decimal places
Revised comment App D-7
John Burnett is a 1979 alumnus of the ABA National Compliance School, and served on its faculty for several years. He graduated with honors with the Class of 1990 from ABA's Stonier Graduate School of Banking, and is also a graduate of the BAIs and the Massachusetts Banker Associations Schools of Banking.John began his banking career in high school when he started as a teller at a $15 million bank that didn't have account numbers for its checking accounts (he says they actually filed by signature!) He joined Cape Cod Bank and Trust Company in 1971 and assumed the position of Compliance Officer in 1976. He also served as corporate secretary and secretary of CCBT's Board of Directors, as well as Clerk of the bank's holding company. John joined Glia Group, Inc. and the BankersOnline.com team in June, 2004. He is a frequent presenter of BOL Learning Connect webinars, and at BOL Conferences events.He was a member of the Massachusetts Bankers Association Legal and Regulatory Compliance Committee, and a former member of the American Bankers Association Compliance Executive Committee and NCS/NGCS Advisory Board. He served on ABA's Truth in Savings Task Force as Regulation DD was being written, and has served on several ABA and Massachusetts Bankers seminar panels.