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With the recent TRID Amendment that takes effect 10-1-2018, we now have a tolerance limit on the disclosed $ amount for “Total of Payments”. Since this is a disclosure that is calculated by our loan origination system, what is the expectation for lenders to monitor that tolerance? And, what do we compare the final disclosure to? TRID requires that we compare APR from between versions of the Closing Disclosure but with respect to the (Total of Payments) disclosure, the LE discloses a 5-yr. term but the CD is a $ amount to the “end” of the term. Would you provide clarification on how to go about “manually” checking that we are within tolerance OR: will our loan origination systems do this automatically?
Also, what is the CURE when we are out of tolerance? Is there a “separate” TRID Cure or do we go by what has always existed by the statute?
Just need general guidance on how to implement a quality assurance step in our process to ensure we are within tolerance and what we are comparing the final disclosure to?
With the recent TRID Amendment that takes effect 10-1-2018, we now have a tolerance limit on the disclosed $ amount for “Total of Payments”. Since this is a disclosure that is calculated by our loan origination system, what is the expectation for lenders to monitor that tolerance? And, what do we compare the final disclosure to? TRID requires that we compare APR from between versions of the Closing Disclosure but with respect to the (Total of Payments) disclosure, the LE discloses a 5-yr. term but the CD is a $ amount to the “end” of the term. Would you provide clarification on how to go about “manually” checking that we are within tolerance OR: will our loan origination systems do this automatically?
Also, what is the CURE when we are out of tolerance? Is there a “separate” TRID Cure or do we go by what has always existed by the statute?
Just need general guidance on how to implement a quality assurance step in our process to ensure we are within tolerance and what we are comparing the final disclosure to?
