TRID Mortgage Originations Flashcards
How is ‘application’ defined?
How does having a completed application impact the delivery requirements for the LE?
TRID defines as application as the submission of a consumer’s financial information for purposes of obtaining an extension of credit.
LE delivery must occur within 3 days of the application
‘Business day’ is defined in (2) different ways.
What are the (2) definitions?
Business day - day that the CU are open to the public
Specific Business day - all calendar days except Sundays and federal holidays
What are the timing requirements for delivering the LE?
When does the CU need to send it?
When is the disclosure considered received?
Sent no later than 3 business days after application for delivery
For mail, add 3 business days
What are the timing requirements for delivering the CD?
When does the member need to receive the disclosure?
3 days prior to consummation
No later than 3 business days before consummation of the loan
What are the restrictions on activities that a CU may not take before the borrower receives the LE and indicates an intent to proceed with the loan?
request income/additional information
What does it mean to provide the disclosures in the LE in good faith?
CU is using best available information
It is considered not in good faith if the charge paid by or imposed on the consumer exceeds the amount originally disclosed regardless if it was a technical error
What are the different tolerance levels for mortgage related services?
Which costs does each level apply to?
0% tolerance- services you cannot shop for
10% tolerance-services you can shop for and we have provided a service provider
no tolerance - services that you shopped for that were not on our service provider list
What tolerance applies if the member is permitted to shop for a mortgage related service?
What tolerance applies to a mortgage related service if the member is not permitted to shop?
10%
0%
If the CU allows a member to shop for a particular mortgage related services, what impact does that have on the tolerance that applies?
What tolerance applies if the member can shop and chooses a provider that is not on the written list of service providers?
10%
no tolerance
In what kind of circumstances may a CU issue a revised LE and use those costs instead of the original LE to determine whether costs charged to the borrower are in good faith?
extra ordinary event beyond the control of the interested parties
inaccurate information at application
new information specific to the consumer and which was not provided at the time of the original LE
Revisions requested by the consumer
interest rate dependent charges (floats)
expiration of the LE
Delayed settlement (construction loans)
