TILA / RESPA INTEGRATED DISCLOSURES WHOLESALE NEWSLETTER VOL.1 “The only thing that is constant is change.” Greek Philosopher, Heraclitus Introduc1on This is the ﬁrst in a series of planned communica)ons and educa)onal forums on how the TILA/RESPA Integrated disclosures (TRID) Rule will impact your rela)onship with CMG. We will oﬀer insights into the changes, sugges)ons for best prac)ces and advance no)ce regarding CMG’s requirements. As with earlier changes, CMG Financial is poised to assist its clients with )mely informa)on, informed guidance and clear communica)on of the impact of these changes. As you work with your vendors, management and staﬀ to prepare for these changes, CMG is commi@ed to assis)ng every step of the way. Overview and Eﬀec1ve Date The TILA/RESPA Integrated disclosures are designed to streamline the some)mes confusing and duplica)ve forms of the Good Faith Es)mate (GFE), Truth-‐in-‐Lending Disclosure (TIL), and the HUD-‐1 Se@lement Statement (HUD). The change goes into eﬀect with applica)ons taken on or a^er August 1, 2015. • No early compliance permi@ed • No late compliance permi@ed • Applica)on dates prior to August 1, 2015 must close using the current documents (GFE, TIL and HUD) The new integrated forms do not apply to the following loan types: • Home Equity Lines of Credit (HELOCs) • Reverse Mortgages • Mortgages secured by a Mobile Home or dwelling not a@ached to real property TRID Highlights In this ﬁrst newsle@er, we want to draw out the larger or more no)ceable changes happening with TRID. • The Ini)al TIL and Good Faith Es)mate have been combined into a Loan Es)mate Form. • The Final TIL and HUD-‐1 Se@lement Statement have been combined into a Closing Disclosure. Items Not Changing Some items will remain the same as you know them today. For instance, an applica)on will be the same with the excep)on of the seventh category of “other”. Therefore, you will s)ll be considered to have an applica)on if you have the following six pieces of informa)on: borrower name, borrower social security number, borrower income (stated not veriﬁed), property value (stated not appraised), loan amount sought, and property address. We will con)nue to update you on items which are remaining the same. Ac1ons to Take • Become familiar with the upcoming changes • Form an internal Task Force to address vendor readiness, determine opera)onal impact and develop staﬀ training. External Resources • CFPB’s “TILA-‐RESPA Integrated Disclosure Rule: Small En)ty Compliance Guide” • CFPB’s website Ques1ons? We will create an FAQ and incorporate key ques)ons and topics in future TRID Newsle@ers. Please, contact us with ques)ons you would like to have addressed in future newsle@ers by e-‐mailing us at TRID@cmgﬁ.com. Contact your Account Executive or Account Manager for full details 3160 Crow Canyon Road, Suite 400, San Ramon, CA. 94583 | 925.983.3000 | NMLS #1820 © 2015 CMG Financial, All Rights Reserved. CMG Financial is a registered trade name of CMG Mortgage, Inc., NMLS #1820 in most, but not all states. CMG Mortgage, Inc. is an equal opportunity lender, licensed by the Department of Business Oversight under the California Residential Mortgage Lending Act No. 4150025, California Finance Lenders Law No. 6053674. Oﬀer of credit is subject to credit approval. For information about our company, please visit us at www.cmgfi.com. To verify our complete list of state licenses, please visit www.nmlsconsumeraccess.org. For more information on State licenses, please visit www.cmgfi.com/ licensing.php. Not intended to serve as a business solicitation for residents in Massachusetts and New York.
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