Comments on: Mortgage Disclosure Improvement Act: New Waiting Periods on Mortgage Transactions

By: Mr. Smith

Mr. Smith — Mon, 17 Aug 2009 14:12:21 +0000

need some clarification on the 3 day waiting period on collecting appriasal fee. If application is taken face to face and disclosures are presented at the time of application, can appraisal fee be collected, or do you still have to wait 3 days?

By: New Mortgage Disclosure Improvement Act Requirements for Real Estate Loans — Salt Lake City Cribs

Fri, 07 Aug 2009 20:46:15 +0000

[...] Some good sources I found on this topic was on the Taylor Bean & Whitaker website, and Rain City Guide. [...]

By: The Federal Reserves proposed changes to Regulation Z (Truth in Lending) | Seattle Real Estate | Rain City Guide

Thu, 23 Jul 2009 16:39:59 +0000

[...] Advertise on Rain City Guide? Recent CommentsMortgage Disclosure Improvement Act: New Waiting Periods on Mortgage Transactions (5) [...]

By: Rhonda Porter

Rhonda Porter — Thu, 23 Jul 2009 14:56:09 +0000

Aubrey Cohen from the Seattle PI referred to this post in his recent article Another Hurdle for Homebuyers

By: Rhonda Porter

Rhonda Porter — Sun, 19 Jul 2009 15:08:35 +0000

Thanks, Apella. I think MDIA has great intentions–making sure that consumers learn about modifications to the terms of their mortgage prior to the closing table. BUT there will be unintended consequences with delayed transactions. I doubt any lender will allow the waiting period to be waived in the event of an emergency.

By: Apella

Apella — Sun, 19 Jul 2009 05:23:30 +0000

Rhonda,

Just wanted to say great post. Loved the Vid and thought that it went great with the message. Just have to love Regs. Thanks again.

By: Rhonda Porter

Rhonda Porter — Thu, 16 Jul 2009 18:50:39 +0000

Tim,

I think there are several “check points” of responsibilty beginning with the loan originator making sure their final APR is not more than 0.125% higher than the last disclosed APR. This can be tricky because at my office, my processor prepared the final loan papers–so she would need to check the final APR and compare to last disclosed–I typically do not see the final TIL… I do review final closing costs and the estimated HUD…but it’s going to boil down to the the APR disclosed on the TIL.

I’m sure funding will also check the APR–however at that point, as you’ve mentioned, we’re dealing with potential delays with closing the transaction.

The key to this will be making sure loan docs go out earlier and that all escrow fees are provided to the lender early on too in order to avoid impacting the APR too close to the closing date.

NOTE: I just added a little video to the post.

By: Tim

Tim — Thu, 16 Jul 2009 18:41:13 +0000

Rhonda,

Who is responsible for making sure that the redisclosure time frame is met if a redisclosure is triggered. Processor? LO? Lender (we have received notice before from a funding dept. that a redisclosure time line had to pass which may have delayed funding by a day or so.)