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June 20, 2015

Un-TIL they make the change! — CFPB’s New Mortgage Disclosure Rule

Filed under: Technical & Legal — Tags: , , , — admin @ 10:22 am

Know Before You Owe!
“The CFPB will be issuing a proposed amendment to delay the effective date of the Know Before You Owe rule until October 1, 2015.”
You can owe without knowing for the time being!

Currently, loan document packages include a Truth in Lending and often a Good Faith Estimate. The problem is that these documents are confusing. The Good Faith Estimate, TIL and HUD-1 have overlapping information and it is often hard to know which document has the final information unless you are a seasoned Notary.

The New Document will be Called “The Loan Estimate.”
This document will cover the loan amount, interest rate, monthly principal & interest, prepayment penalty info, balloon payment info, estimated monthly payments, tax, insurance, closing costs, and more.
http://files.consumerfinance.gov/f/201311_cfpb_kbyo_loan-estimate.pdf

The APR Revisited
In addition to starting the APR on page three, there will be yet another figure to make Notaries crazy called the TIP which is the Total Interest Percentage which reflects the total amount of interest you will pay over the life of the loan as a percentage of the loan amount.

Other Considerations
Late payment fees, servicing, assumption, and appraisal costs will also be covered in this new and exciting document.

Is Change Good?
Honestly, this new document is somewhat of a combination of the HUD-1 and the TIL with some elaborations and improvements. I believe it is not necessary to create a new name for a document. In my opinion, this information would be better off added to existing documents so that Notaries and borrowers don’t get any more confused than they already are.

What Do Notaries Think?
Deb on LinkedIn feels that this new document will make life simpler.
Wendell on LinkedIn feels that the new forms are not any more complicated than the forms they replace.
Linda on LinkedIn feels the new forms will help Notaries as borrowers will have the chance to look the form over and learn the facts before the signing.
Kelly states that there will be a complete process change for loans in the industry and it will be more than just one new form.
https://www.linkedin.com/grp/post/4139192-6014441719272067073?trk=groups-post-b-all-cmnts

You might also like:

Technical Points for Notaries
http://blog.123notary.com/?p=14492

TRID information courtesy of Carmen
http://blog.123notary.com/?p=18932

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