Friday, October 2, 2015

Be Prepared for Longer Closing Timelines


On October 3, 2015, the Consumer Finance Protection Bureau (CFPD) will be implementing the new TILA-RESPA Integrated Disclosure (or TRID, for short). It replaces the Truth-In-Lending Disclosure and Good Faith Estimate for most mortgage loans. The CFPB was created by the Consumer Protection Act of 2010 (also known as Dodd-Frank, named after the congressmen who got it passed) in an attempt to prevent the recurrence of the financial crisis of 2008.

The new disclosure is purported to be easier for consumers to read and understand, as well as provide more information and stricter requirements of the process. It tightens up waiting periods and tolerances for certain quoted fees and requires the creditor to supply a list of providers for which the consumer may shop services.

You can view the sample forms HERE. For the most part, I think they do make the information more easily digestible, although depending on how your specific state does things there will be some discrepancies. For instance, in Colorado, where clients receive a discount on title insurance at the time of purchasing both a homeowner and lender policy, arriving at the right totals in the right boxes may be a bit confusing.

Another thing consumers should be aware of is potentially longer timeline to close the transaction. The addition of a three-day waiting period between borrowers receiving the closing disclosure and closing the deal is now mandatory and cannot be waived by the borrowers. Any changes made at that point to the annual percentage rate, the loan product, or the prepayment penalty will start the three-day clock over again.

While professionals in the real estate and mortgage industry should be ready for compliance, I would recommend adding a week or so to your expectations when it comes to getting those final documents. It's usually easier to move a closing up if everyone is ready, than to try to push it back.


I would love to help you with your real estate journey. 
Please contact me at 303-917-7143 or robbin@stauferteam.com

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