October 3rd is just around the corner and we are happy to share that our title quote app is ready for the change.
Before the Loan Application is filed
The TILA/RESPA Integrated Disclosure rule makes a clear distinction between two phases, one before the consumer fills in a loan estimate, and one right after that event. The phase before, we’ll call it the “pre-disclosure” phase, while the one after, the “disclosure” phase. Our title quote app is extremely valuable in the “pre-disclosure” phase, due to the wide range of tools it features:
THE TITLE QUOTE TOOL
This is a very simple but effective tool that allows everyone to see the specific title fees and recording & transfer taxes for a particular transaction.
THE BUYER ESTIMATE
This estimate tool (probably the most accurate one on the market) is created specifically for the lender to allow him/her to issue out a “preliminary written estimate”, before being required to put out an official Loan Estimate. It’s designed to get the consumer to that point.
THE SELLER NET SHEET TOOL
This is probably the most detailed seller net sheet tool Realtors will ever get their hands on. It’s designed to allow the seller to really see what he/she will net after the transaction is done.
ALTA Settlement Statements
Whether we’re talking about an estimate to the buyer/borrower or to the seller, the ALTA forms provide an alternative way of issuing these estimate, again, before TRID requires the use of a Loan Estimate or Closing Disclosure form.
THE PRE-HUD WILL STILL BE THERE
The TRID rule still indicates the use of a HUD-1 form for transactions that are not subject to the rule (cash deals, commercial or some marginal types of mortgages, HELOC, reverse-mortgages, etc.
After the Loan Application is filed
The best place for Lenders to get your title fees and recording & transfer charges.
Once the consumer fills in a Loan Application, the Lender is required to issue a Loan Estimate form. Before closing, he/she will have to send out the Closing Disclosure. These are the only two forms that can be used, no other types of estimates or disclosures will be permitted from this point on.
TITLE QUOTE – The Loan Estimate View
We will be offering a “Loan Estimate” view to the Lenders who need title fees and recording and transfer charges, to put them into the actual Loan Estimate form. The “Loan Estimate View” will detail all these numbers, but have them broken down by their respective sections on Page 2 of the Loan Estimate, so that the Lender can easily pick them up when filling in the official form.
The app will follow TRID’s guidelines in what concerns “preliminary written estimates”, but also incorporate some of the regulations that concern the Loan Estimate and Closing Disclosure, for consistency:
- The app will use the TRID formula to split between lender’s policies and owner’s policies when in a simultaneous issue situation.
- The Buyer Estimate as well as any ALTA Settlement Statement addressing the Buyer/Borrower will feature special language required by TRID (eg. “Your actual rate, payment, and costs could be higher. Get an official Loan Estimate before choosing the loan.”) – (§ 1026.19(e)(2)(ii); Comment 19(e)(2)(ii)-1)
- The afore mentioned forms/estimates that concern the buyer/borrower will not have headings, content and format substantially similar to the Loan Estimate or Closing Disclosure. (§ 1026.19(e)(2)(ii); Comment 19(e)(2)(ii)-1)
- The App will not feature a “Preliminary Loan Estimate” or a “Preliminary Closing Disclosure” form as those are not compliant, as they violate the previous rule.
- The Pre-HUD tool will still be found in the app, for transactions NOT AFFECTED by TRID.
Frequently Asked Questions
Will the app offer Loan Estimate and Closing Disclosure forms?
The title quote app is an estimate tool, to be used in the pre-disclosure phase. The Loan Estimate and Closing Disclosure forms are official forms to be used in strict observance of the TRID rule. At this point, the app does not offer these forms. It does however offer a Loan Estimate View of the Title Quote, useful to the Lender, when filling in the Loan Estimate form.
Will Lenders be able to use the Buyer Estimates and ALTA Settlement Statement Buyer/Borrower tools in the app?
Absolutely yes, HOWEVER, only before receiving a loan application. After this, the lender will only be allowed to use the Loan Estimate and Closing Disclosure form.
Will the title quote app offer a “Preliminary Loan Estimate” or a “Preliminary Closing Disclosure” tool?
The TRID rule totally prohibits issuing forms that look substantially similar to the Loan Estimate or Closing Disclosure forms. So, the answer to this question is no.
If you have any questions regarding the app or TRID please click here and we will reach out to you.
*Lenders: For the remainder of the year, please specify Closing Disclosure or HUD when submitting your order.