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Since the topic for this week’s group meeting is Q&As for the new disclosures, I thought I’d go ahead and post a couple of questions that I have. I figure it might make it easier on Jack and group to have some to start with! I apologize if these seem simple, but the more I look at this stuff the more confused I feel!
Appraisal Notice – I am assuming that to show that we delivered the copy of the appraisal at least 3 days prior to closing that we will still need to document when it was delivered even though it is on the disclosure page of the CD?
Seller’s signatures – I assume that to get the sellers to sign a copy of the CD, we will have to use an addendum since none of the sample disclosures have lines for the sellers to sign?
Credit report fee – In the past we have always disclosed the credit report fee (POC-L or an offsetting lender credit) because it is a cost of the loan even though we have never collected that fee from the customer, but I am questioning it now. Do we even have to disclose it if we will never collect it from the borrower? I have read some conflicting opinions on this.
Homeowners/taxes disclosed – Since we do require taxes and insurance to be paid during the life of the loan (but not always at closing for refinances) we have disclosed those as POC-B. On these new disclosures, if we are not collecting any funds at closing for these, do we list these in section H – Other so those amounts are not included in the Cost to Close section? Or how should we disclose these?
I’m looking forward to this week’s session to see what everyone else is questioning!
I would like to add to this list of questions. I’m still a little confused by closed end loans with a consumer purpose secured by commercial property. For example: a consumer customer applies for a loan to purchase a second home but plans to use their commercial building that they own free and clear as collateral. It appears to me that since this is a closed-end consumer credit transaction secured by real property we would have to provide the applicant(s) with a Loan Estimate. Right?
I for one am so happy the effective date was pushed back. I’m still trying to finish training our loan team so I want to make sure all the bases are covered…….as much as possible! Thank you.
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