CFPB/TRID: What You Need to Know as a Real Estate Agent
CFPB / TRID goes into effect October 3rd & these changes will have an impact on the lending process & on the Closing Process. Please take a class on these changes! Go to the MX1 Training Calendar & Register for: "Show Me the Money & Get Me to Closing." Also, make sure you utilize the Maximum One Affiliated Lenders & Closing Attorneys for fabulous communication as the industry goes through this transition. Lender & Attorney contact information located at the bottom of this newsletter & on the MX1 Blog under "Vendors." More information is on the Extranet under "CFPB - TRID Information" Considerations for You as an Agent: • Check on repairs at least 10 - 14 days PRIOR to closing. If the Buyer & Seller end up negotiating financially for repairs which have not been completed, this may have to be re-disclosed on the Closing Statement. Ensure plenty of time for these re-disclosures so as not to delay closing. • Schedule closings mid-month & at the beginning of the week. • Many Lenders (especially large banks) will be preparing the Closing Disclosure - NOT the Closing Attorney. • Lenders preparing Closing Disclosure may NOT have accurate nor current HOA documents - which will inevitably cause a delay & the requirement of a new HOA Transfer Letter or Disclosure Letter which will cost the Buyer or Seller money. • Contracts binding under the RE Forms Contract do NOT allow for a Unilateral Extension of Closing Date - if Buyer's Lender must re-disclose & cause a delay, if Seller does not agree to an extension, Buyer will default on the contract. • Consider scheduling closing PRIOR to the actual end date of the contract. • Closings may take closer to 2 hours • Be on time to closings or they may be re-scheduled • Lenders & Attorneys may only send encrypted email • Lenders & Closing Attorneys may NOT send you a preliminary Closing Disclosure • Closing Attorneys may not send you wire instructions - only to the Buyer • Lenders must follow strict time frames based on mandated guidelines • Buyers MUST acknowledge receipt of Closing Disclosure • Closing Attorneys will have more locked doors in their offices & you will not be able to walk through office unescorted • HOA letters WILL be an issue & you will more than likely need 2 letters - negotiate up fron who will pay for these & set the proper expectations • Determine who you are to send your Commission Instructions to - the Lender or the Attorney • Pay-at-Close may not be honored by Closing Attorneys due to limited space on the new Closing Disclosure • The Brokerage Firm Number must be included on the Closing Disclosure • Your License Number must be included on all Closing Disclosures • Back-to-Back closings will be EXTREMELY Difficult due to potential re-disclosure issues • Hazard Insurance must be paid-in-full prior to closing • Schedule Closings at LEAST 45 days from Binding Agreement Date • Agents may not use Closing Attorney's computers (i.e. to print an Amendment) so bring your file with you & Blank Amendments • The Key for you as an agent is to stay in constant and meaningful communication with the Lender and Closing Attorney as well as your clients, customers and co-op agents. • Stay as informed and current as possible on the impact of these changes. • As they changes first become enacted, it will be vital to utilize Lenders & Closing Attorneys whom you know, love, trust & have a good relationship - especially the Maximum One Affiliated Closing Attorneys & Lenders • Remember that PATIENCE is a virtue! Links to More Information: Terms & Definitions: http://www.realtor.org/topics/trid-ti... Loan Estimate TImeline & What Defines Loan Application: http://MAX705-connect.globalwolfweb.c... How to Count 3 Days: http://MAX705-connect.globalwolfweb.c... Sample Closing Disclosure: http://MAX705-connect.globalwolfweb.c... Sample Seller's Closing Disclosure: http://MAX705-connect.globalwolfweb.c... Previous MX1 Video with Additional Information: • CFPB Impact on Closings as of 8/1/15 NAR Video: TRID http://www.realtor.org/topics/trid-ti... NAR Information: Know Before Owe: http://www.consumerfinance.gov/know-b...