TILA RESPA Integrated Disclosures (TRID)

Loans sold to Union Home Mortgage Corp. Wholesale must comply with all federal and state regulations as well as Union Home Mortgage Corp. Wholesale guidelines. This information is for guidance purposes only and should not

replace consultation with your Legal and Compliance resources. Equal Housing Lender: Union Home Mortgage Corp. Wholesale. Corporate Office: 8241 Dow Circle West, Strongsville, OH 44136. All rates and programs are subject to

change at any time without notice. Union Home Mortgage Corp.

NMLS ID 2229

For mortgage originating professionals only; not authorized for distribution to consumers.

DISCLAIMER

• The content in this presentation is for general informational purposes only. This presentation does not represent legal interpretation, guidance or advice from Union Home Mortgage Corp.. While efforts have been made to ensure accuracy, this presentation is not a substitute for the rule. Only the rule and its Official Interpretations can provide complete and definitive information regarding requirements. This document does not bind Union Home Mortgage Corp. and does not create any rights, benefits, or defenses, substantive or procedural, that are enforceable by any party in any manner.

• You are advised to consult your own compliance staff or attorney regarding your specific residential mortgage lending questions or situation to ensure your compliance with applicable laws and regulations.

Topics Covered

• TRID Overview • Consent To Do Business Electronically • Electronic Delivery Process • Loan Estimate • Tolerance Limits • Revised Loan Estimate • Closing Disclosure • Revised Closing Disclosure • TRID Mail Delivery Calendar • TRID Electronic Delivery Calendar • Key Take-Aways

WHAT IS TRID?

• Applicable on all loan applications dated on or after October 03, 2015.

• Loan applications taken prior to October 03, 2015 will follow existing process requiring GFE, TIL, and HUD-1.

• The new Loan Estimate (LE) is a combination of, and replaces the Initial Truth-In Lending disclosure (TIL) and Good Faith Estimate (GFE)

• The new Closing Disclosure (CD) is a combination of, and replaces the Final Truth-In Lending disclosure and RESPA HUD-1.

• TRID introduces new timing requirements for disclosures.

• TRID introduces new tolerance levels for disclosed estimates.

• TRID introduces new Pre-Disclosure requirements.

• Purchase transactions require the new “Your Home Loan ToolKit” form which replaces the current “Settlement Information Booklet”. “Your Home Loan ToolKit” form can be downloaded at http://www.consumerfinance.gov/learnmore/#respa

• Effective 10/12/2015, Union Home Mortgage Corp. will no longer accept any file with an application date prior to October 3, 2015.

Electronic Delivery Consent Form

• If any loan disclosures are delivered to the borrower

electronically or e-signed, Union Home Mortgage must have a copy of the consumers “Consent To Do Business Electronically” form that was delivered and acknowledged by the consumer prior to the loan disclosures being delivered to them.

• If documents were delivered to the consumer electronically and the proof of consumers consent to receive documents electronically cannot be provided, Union Home Mortgage will not accept the submission.

Electronic Delivery Consent Form

• Union Home Mortgage will deliver any necessary re-disclosure to the borrower

electronically. • Union Home Mortgage must provide a “Consent To Do Business Electronically”

form to the borrower as the consent provided by the broker will not cover the documentation provided electronically by Union Home.

• “Consent To Do Business Electronically” form will be electronically sent to all

individuals involved in the transaction (including non-borrowing owners on rescindable transactions) using the email address provided on the brokers loan submission sheet. This form will be sent at the time of loan set-up.

• If the consumer does not consent to receive documents electronically, all disclosures must be mailed or hand delivered to the borrower and wet-signed. Union Home Mortgage will not email documents to the consumer. In this case, the documents will be placed in the efolder by the UHM Broker Coordinator and the Broker will be responsible for retrieving them from the TPO Portal and having them executed.

Electronic Delivery Consent Form

• This is an example email notification that will be received by the borrower when the “Consent To Do Business Electronically” form is sent out by Union Home Mortgage.

Electronic Delivery Consent Form

• The Broker and Broker Processor will be included as additional recipients of notifications when documents are sent to the borrower electronically. Below are examples of email notifications that the broker and broker processor will receive:

NEW DISCLOSURE OVERVIEW

Loan Estimate

• Union Home Mortgage will accept the Brokers initial Loan Estimate. The Broker will be required to provide the locked LE if loan was locked prior to submission to Union Home Mortgage.

• Brokers are expected to make a “good faith effort” to disclose the lenders name, address, and loan ID on the initial LE. If a broker does not know the end lender, the lender info on the LE should be left blank. Union Home Mortgage will not accept a submission that lists another lenders name and/or address on the initial Loan Estimate.

• Union Home Mortgage will be responsible for all re-disclosures of the Loan Estimate for changes that occur after loan submission.

• Lender Paid vs Borrower Paid compensation on the Loan Estimate

– Lender paid compensation charge will not show on the Loan Estimate but is still included in the points and fees test. It will show on the CD.

– Borrower paid compensation will show in box “A. Origination Charges”

– Box “A. Origination Charges” on the LE only shows fees paid directly by the borrower to compensate the broker of lender.

Loan Estimate

• N/A is not permitted

• Cross-outs are not permitted

• Alphabetical order for fee names

• Title fees are displayed: “Title –”

• Union Home Mortgage has developed a fee matrix that should be used when preparing your LE. This has been posted to www.uhwholesale.com

• Intent to Proceed and Acknowledgement of Receipt of LE must be executed by the borrower.

LE Page 1

• Provides General Loan Info

• Loan Terms • Payments over the life of

the loan • Estimated closing cost • Estimated cash to close

– If refi this will indicate if borrower is bringing cash or getting cash

• Indicates if rate is locked.

LE Page 2

• Fee naming should be consistent with the UHM Fee Matrix.

• Fee naming should be in alphabetical order

• Dollar amounts are rounded to whole numbers

• Title charges must be labeled “Title – “

• Lender Credits including YSP are shown in the Lender Credits section as a negative number

LE Page 3

• Shows lender information. Lender info must be left blank or contain Union Home Mortgage Name, address, NMLS Number, and contact information. UHM will not accept a submission if the initial LE contains another lenders information.

• Loan Estimate must be signed if there is a signature line. Signature does not indicate Intent To Proceed

TOLERANCE LIMITS

• Zero Tolerance Restriction:

– Fees paid to the creditor, mortgage broker or affiliates

– Fees paid to an unaffiliated third party if borrower was not permitted to shop

– Transfer Taxes

• 10% Cumulative Tolerance Restriction:

– Recording Fees

– Charges for third-party services where the charge is not paid to the creditor or the creditor’s affiliate, or:

– Consumer is permitted to shop, but selects a service provider on the creditor’s written list of service providers

• No Tolerance Restriction:

– Pre-paids, Property Insurance Premiums, and amount placed in escrow

– Fees paid to 3rd-party service providers selected by consumer not listed on service provider list provided to borrower

– Fees paid for 3rd-party services not required by creditor

Loan Estimate Re-Disclosure/Change of Circumstance

• Union Home Mortgage accepts the brokers initial LE disclosed to the consumer, but Union Home Mortgage is legally responsible. LE’s may not be reissued to correct miscalculations, underestimation of charges, or errors.

• A revised LE may be issued when: – Changed Circumstance Affecting Settlement Charges – Changed Circumstance Affecting Eligibility – Revisions Requested by the Consumer – Interest Rate Dependent Charges – Expiration

Loan Estimate Re-Disclosure/Change

of Circumstance

• As long as the “Consent To Do Business Electronically” has been acknowledged, all re-disclosures will be delivered to the consumer electronically.

• Broker and Broker Processors will be included as

additional notification recipients when re-disclosures are sent out. You will know when the items were sent to the consumer and when they were received by the consumer.

CLOSING DISCLOSURE

• Union Home Mortgage will work closely with closing agents in the preparation of the CD. Union Home will be responsible for the delivery of the Borrowers CD. The closing agent will be responsible for the sellers side in the case of a purchase.

• Union Home Mortgage will be vetting settlement agents for risk through a third party provider. We ask that the following items be provided at submission to expedite this process: CPL, E&O Ins. Policy, Wiring Instructions, and Fidelity Bond

• Union Home Mortgage will work with settlement agents via our LOS to electronically obtain title fees.

• Union Home Mortgage will deliver the CD electronically to the consumer as long as the “Consent To Do Business Electronically” form was acknowledged.

CLOSING DISCLOSURE

• The CD must be received and acknowledged by the consumer no

later than 3 business days prior to consummation. • Refinances – ALL individuals with the right to rescind, including non-

borrowing owners must receive and acknowledge the CD prior to consummation. Please provide the contact information, including the e‐mail address, for all individuals with the right to rescind when submitting the loan.

• Consummation can only occur 3 business days from the

acknowledgment of receipt of the CD. If acknowledgement is not received, consummation can occur 6 business days from the date the CD was sent.

REVISED CLOSING DISCLOSURE

• The Closing disclosure may be reissued after the initial CD is sent

out. Some changes will require a new 3 day waiting period to begin after acknowledgement by the consumer.

• New 3 day waiting period required:

– If APR increases by more than .125% – Loan product change (fixed to adjustable rate) – Addition of a prepayment penalty

• Changes that do not require new waiting period and can be disclosed on closing CD: – Increase to hazard insurance premium – Inspection reveals broken appliance, seller agrees to adjustment

TRID CALENDAR MAIL DELIVERY

TRID CALENDAR

ELECTRONIC DELIVERY

KEY TAKE-AWAYS

• Effective 10/12/2015, Union Home Mortgage Corp. will no longer accept any file with an application date prior to October 3, 2015.

• Consent To Do Business Electronically form must be provided to consumer prior to electronic

delivery of any documentation. Consent form must be delivered with loan packages that had electronically delivered docs. Submission cannot be accepted by UHM if proof of consent cannot be provided.

• Broker to provide all consumer contact information especially accurate email to expedite delivery of disclosures (including non-borrowing owners if rescindable)

• Ensure that lender information on the LE is either blank or contains Union Home Mortgage Corp. information. If another lender is listed on the LE, UHM will not accept the submission

• Disclose all fees accurately on the LE utilizing UHM Fee Matrix.

• Disclose the full amount of the premium for the lender’s title insurance without any adjustment to the premium that might be made for the simultaneous purchase of an owner’s title insurance policy.

• Lender Paid: Compensation is not shown on the LE

• Borrower Paid: Compensation is shown on the LE in “A. Origination Charges”

KEY TAKE-AWAYS • Must have Intent To Proceed and Acknowledgement of Receipt with initial submission package

• Must have Settlement Service Provider List with initial submission package- SSPL must indicate whether

borrower can shop/did shop

• Union Home Mortgage will be vetting settlement agents for risk through a third party provider. We ask that the following items be provided at submission to expedite this process: CPL, E&O Ins. Policy, Wiring Instructions, and Fidelity Bond

• Purchase transactions require the new “Your Home Loan ToolKit” form to be provided to consumer within three days of application which replaces the current “Settlement Information Booklet”. “Your Home Loan ToolKit” form can be downloaded at http://www.consumerfinance.gov/learnmore/#respa

• All individuals with right to rescind must receive and acknowledge the CD at least three business days prior to consummation. This included non-borrowing owners.

• Please pay attention to the email notification that e-disclosures have been sent to the consumer. It is vital that Brokers work with their consumers to quickly receive, review, and acknowledge the e-disclosure consent form and e-disclosures so that the required waiting periods can begin and the process is not delayed.

• We also ask that Brokers work diligently to get all conditions submitted quickly to ensure that target closing dates are met.

AUDIENCE QUESTIONS

Q. Does the broker need to send a LE with submission or can we let Union Home disclose? A. Union Home will not disclose the initial LE. The broker needs to issue the initial LE. Q. Do we have to wait a week until we can order an appraisal? A. No. The appraisal can be order when the initial Intent To Proceed is received from the consumer. Q. If a loan switches from lender paid to borrower paid compensation, is that a re-disclosure of the LE? A. Yes Q. Can the Consent to Receive Electronic Documents be sent with original package for signature or do we have to send prior to. And can it be sent electronically? A. It can be sent with the initial package and it can be sent electronically. Q. Before the CD is sent out, can we make any small reductions to title fees etc. as we can now after we see it? A. Yes

AUDIENCE QUESTIONS Q. Is it okay for broker name to be on the LE? A. Yes Q. Do you have a specific Consent to Receive Electronic Documents form or can we use the Calyx form? A. We do not have a specific form and the Calyx version can be used. Q. Is acknowledgement of LE the actual signed LE? A. No. With the initial LE we require receipt of the Acknowledgement of Receipt of Loan Estimate form as well. Q. If the broker issues the LE, do we have to submit a full submission package within 3 days? A. No. Q. A Non borrowing spouse does not need to acknowledge until the initial CD correct? A. That is correct.