CORRESPONDENT Compliance Manual. Instructions to Complete the TRID Loan Estimate

Transcription

1 CORRESPONDENT Compliance Manual Instructions to Complete the TRID Loan Estimate Compliance Department 9/14/ Impac Mortgage Corp. NMLS # Rates, fees and programs are subject to change without notice. Other restrictions may apply. Information is intended solely for mortgage bankers, mortgage brokers, financial institutions and correspondent lenders. Not intended for distribution to consumers, as defined by Section of Regulation Z, which implements the Truth-In-Lending Act. Licensed by the Department of Business Oversight, under the California Residential Mortgage Lending Act (License # ). Compliance: TILA-RESPA Integrated Disclosures (TRID) Page 1 of 26 Version

2 Effective October 3, 2015 General Instructions The lender is required to make the information on the Loan Estimate clearly and conspicuously in writing, in a form that the borrower may keep. The disclosures also shall be grouped together and segregated from everything else. Unless otherwise permitted below, the disclosures shall be made in the same order, and positioned relative to the master headings, headings, subheadings, labels, and similar designations in the same manner, as shown in Loan Estimate template. If a master heading, heading, subheading, label, or similar designation contains the word estimated or a capital letter designation, that heading, label, or similar designation shall contain the word estimated and the applicable capital letter designation. Unless otherwise permitted below the Loan Estimate template must be used The Loan Estimate may be provided to the borrower in electronic form, subject to compliance with the borrower consent and other applicable provisions of the Electronic Signatures in Global and National Commerce Act (ESIGN Act) Exceptions Unit-period. Wherever Loan Estimate uses monthly to describe the frequency of any payments or uses month to describe the applicable unit-period, the lender will substitute the appropriate term to reflect the fact that the transaction s terms provide for other than monthly periodic payments, such as bi-weekly or quarterly payments. Translation. The form may be translated into languages other than English, and lender may modify the Loan Estimate template to the extent that translation prevents the headings, labels, designations, and required disclosure items under this section from fitting in the space provided. Logo or slogan. The lender providing the form may use a logo for, and include a slogan with, the information required by section (a)(3) in any font size or type, provided that such logo or slogan does not cause the information required by section (a)(3) to exceed the space provided for that information. If the lender does not use a logo for the information required by section (a)(3), the information will be disclosed in a similar format as the Loan Estimate template. Business card The lender may physically attach a business card over the information required to be disclosed by section (a)(3). Administrative information The lender may insert at the bottom of each page under the disclosures required, any administrative information, text, or codes that assist in identification of the form or the information disclosed on the form, provided that the space provided in the Loan Estimate template is not altered. Rounding Generally all amounts on the Loan Estimate are rounded to next highest dollar amount and truncated with the exception of the loan amount which not rounded however does not show cents, and the principal and Interest payments, prepaid interest, escrow impounds which show the show exact amounts with cents. Percentage amounts may not be rounded and should be shown up to two or three decimals, as needed, except where noted. If a percentage amount is a whole number, show the whole number only with no decimals Consummation Occurs when the borrower becomes contractually obligated to the lender on the loan, not, for example, when the borrower becomes contractually obligated to a seller on a real estate transaction. The point in time when a borrower becomes contractually obligated to the lender on the loan depends on applicable State law. Compliance: TILA-RESPA Integrated Disclosures (TRID) Page 2 of 26 Version

3 Loan Estimate Page 1 General Information Section Instructions to complete the General Information section on the top of Page 1 Field ID Name of Field Requirement (a)(1) Loan Estimate Form must be titled Loan Estimate. This is HARDCODED on the form. (a)(2) Save this Loan Estimate to Form Purpose must state exactly this phrase. Save this Loan Estimate to compare with your Closing Disclosure. This is HARDCODED on the form. compare with your Closing Disclosure (a)(3) Bank Name Enter the name and address of the Lender. Wholesale Loans: Do NOT enter the brokers name and address on the LE. If the broker does not reasonably know at the time the Loan Estimate is provided to the borrower who the lender will be, then this field may be left blank. If the broker knows the borrower s application will be submitted to the lender, then Lender s name is listed on the LE. If the lender reviews the LE BEFORE the broker provides a copy to the borrower, then the lender s name is listed on the LE If the broker submits the borrower s application to more than one lender, then this field may be left blank. (a)(4) DATE ISSUED Enter the date the disclosures are mailed or delivered to the borrower by the Lender (a)(5) APPLICANTS Enter the name and mailing address of the borrower(s) applying for the credit. Use each Borrower s name and mailing address if there are multiple Borrowers. An additional page may be added to the Loan Estimate if the space provided is insufficient to list all of the Borrowers. (a)(6) PROPERTY Enter the property address, which MUST include the zip code of the property. If the property address is unavailable, enter a description of the property(i.e. lot number) and ALWAYS include a zip code. (a)(7) SALE PRICE OR EST. PROP. VALUE Personal property such as furniture or appliances that also secures the loan may be, but is not required to be included as Property. An additional page may not be appended to the Loan Estimate to disclose a description of personal property Depending on the transaction, this field will ask for the Sales Price or the Estimated Property Value. Purchase Money Loans: Enter the contract sale price of the property identified. Property. If personal property is included in the Sale Price of the Property, use that price without any reduction for the appraised or estimated value of the personal property. Compliance: TILA-RESPA Integrated Disclosures (TRID) Page 3 of 26 Version

4 Refinance Loans: Enter the estimated value of the property identified. (a)(8) LOAN TERM Enter the full term of the loan stated in years or months, or both, as applicable. Describe the Loan Term as years when the Loan Term is in whole years. For example 1 year or 30 years. For a Loan Term that is more than 24 months but is not whole years, describe using years and months with the abbreviations yr. and mo., respectively. For example, a loan term of 185 months is disclosed as 15 yr., 5 mos. For a Loan Term that is less than 24 months and not whole years, use months only with the abbreviation mo. For example, 6 mo. or 16 mo. (a)(9) PURPOSE Select one from the following: Purchase Refinance Construction Home Equity Loan (a)(10) PRODUCT The description of the loan features that may change the periodic payment. Select from the following: Interest Only: if one or more payments may be applied only to accrued interest Description of Loan Product: Select from the following: Adjustable Rate: if the interest rate may increase after consummation Fixed Rate The description of the loan feature must precede the description of the loan product. If the transaction has more than one of the loan features, the Lender shall disclose only the first applicable feature in the order the features are listed above. The descriptions must each be preceded by the duration of any introductory rate or payment period, and the first adjustment period, as applicable. Examples: Fixed Rate 5 Year Interest Only 5 Year Interest Only, 5/3 Adjustable Rate When there is no introductory period for an Adjustable Rate, disclose 0. For example: a product with no introductory rate that adjusts every year after consummation is a 0/1 Adjustable Rate. When the time periods disclosed in are not in whole years, disclose the applicable fraction of a year by use of decimals rounded to two places. For time periods of 24 months or less, disclose the number of months with the abbreviation mo. For example: An Adjustable Rate Product with an introductory interest rate for 31 months that adjusts every year thereafter is a 2.58/1 Adjustable Rate. An Adjustable Rate Product with an introductory interest rate for 18 months that adjusts every 18 months thereafter is an 18mo./18mo. Adjustable Rate. a product with an introductory rate that is fixed for the first five years and adjusts every three years starting in year 6 is a 5/3 Adjustable Rate. (a)(11) LOAN TYPE Enter the type of loan offered using one of the following terms: Conventional FHA VA Other (provide brief description). Example USDA (a)(12) LOAN ID # Enter the Loan Number of the Lender. Wholesale Loans: Do NOT enter the brokers Loan Number on the LE. If the broker does not reasonably know at the time the Loan Estimate is provided to the borrower who the lender, then this field may be left blank. If the broker knows the borrower s application will be submitted to the lender, then Lender s name is listed on the LE. If the lender reviews the LE BEFORE the broker provides a copy to the borrower, then the lender s name is listed on the LE If the broker submits the borrower s application to more than one lender, then this Compliance: TILA-RESPA Integrated Disclosures (TRID) Page 4 of 26 Version

5 field may be left blank. (a)(13) RATE LOCK Identify if the interest rate is locked or not. Loan Terms Section If Yes - Enter Yes and the date and time (including the applicable time zone) when the rate lock period ends, include a specific statement with the expiration of other closing costs. Example Yes 8/31/14 at 5:00p.pm. PDT. Before closing, your interest rate, points, and lender credits can change unless you lock the interest rate. All other estimated closing costs expire on 8/17/2014 at 5:00 p.m. PDT If No - Enter No and include a specific statement with the expiration of other closing costs.. Example: No Before closing, your interest rate, points, and lender credits can change unless you lock the interest rate. All other estimated closing costs expire on 8/17/2014 at 5:00 p.m. PDT Note: time zone is determined by the lender. So if the lender is located in PDT and the property is in EDT the lender may choose PDT. Instructions to complete the Loan Terms section on Page 1 Field ID Name of Field Requirement (b)(1) Loan Amount Enter the loan amount. Do not round and do not show cents (b)(8) Enter a NO to indicate that the loan amount will not increase after consummation, under the heading Can this amount increase after closing? Consummation is the date the Note/Security Instrument is signed by the borrower (b)(2) (b)(8) Interest Rate Timing Note: a YES is used for example on Negative Amortization loans. Since IMC does not make or purchase Neg. Am. Loans, this document is not addressing a Yes response. Fixed Rate: Enter the interest rate that will be applicable at the time of consummation followed by a NO indicating the amount will not increase after consummation. If the interest rate is a whole number truncate the decimal point. Do not round. Examples 4.00% = 4% 4.5% =4.50% Maximum is 3 decimal places Consummation is the date the Note/Security Instrument is signed by the borrower Compliance: TILA-RESPA Integrated Disclosures (TRID) Page 5 of 26 Version

6 IO ARM: Enter the interest rate that will be applicable at the time of consummation If the interest rate at consummation is not known, then enter the fully-indexed rate (index value + margin at the time of consummation) Enter a YES Enter a YES to reflect the interest rate may increase after consummation Enter the frequency of interest rate adjustments Enter the date when the interest rate may first adjust Enter the maximum interest rate, truncated, and the first date when the interest rate can reach the maximum interest rate Enter statement See AP Table on Page 2 for details (b)(3) & (b)(6) (b)(8) Monthly Principal & Interest Can this amount increase after closing? Timing The dates disclosed is the year in which the event occurs, counting from the date that interest for the first scheduled periodic payment begins to accrue after consummation. Fixed Rate: Enter the initial monthly principal and interest payment (P&I), include cents Enter a No to reflect the P&I payment will not adjust Verify the statement See Projected Payments below for your Estimated Total Monthly Payment appears. (HARDCODED) IO ARM: Enter the initial monthly P&I payment, include cents If the interest rate at consummation is not known, then the amount disclosed is calculated using the fully-indexed rate (index value + margin at the time of consummation). Enter a YES to reflect the P&I payment will adjust Enter the frequency the P&I payment will adjust and the due date of the first adjustment Enter the maximum possible P&I payment, rounded to the nearest whole dollar, and the date when the P&I payment may first equal the maximum P&I payment Enter whether the payment includes interest only and for how long Enter statement See AP Table on Page 2 for details (b)(4) (b)(7) (b)(8) Prepayment Penalty Does this loan have these features? Timing The dates disclosed is the year in which the event occurs, counting from the date that interest for the first scheduled periodic payment begins to accrue after consummation. Enter YES or NO if there is a prepayment penalty. If Yes Enter the maximum amount of the prepayment penalty and the year the penalty ends, rounded to the nearest whole dollar Thee date disclosed is the year in which the event occurs, counting from the date of consummation. Prepayment Penalty means a charge imposed for paying all or part of a transaction s principal Compliance: TILA-RESPA Integrated Disclosures (TRID) Page 6 of 26 Version

7 (b)(5) (b)(7) (b)(8) Balloon Payment Does this loan have these features? before the date on which the principal is due, other than a waived, bona fide third-party charge that the lender imposes if the borrower prepays all of the transaction s principal sooner than 36 months after consummation. Enter NO if there is a balloon payment Balloon Payment means a payment that is more than two times a regular periodic payment.. IMC DOES NOT MAKE OR PURCHSE BALLOON LOANS Projected Payment Section Instructions to complete the Projected Payments section on Page 1 The Projected Payments table shows estimates of the periodic payments that the borrower will make over the life of the loan. The table provides an itemization of each separate P&I payment or range of P&I payments, together with an estimate of taxes, insurance, and assessments and the payments to be made with escrow account funds. If any of the triggering events listed below may occur during the life of the loan, add a column to show the amount of the periodic payments after the triggering event. The principal and interest payment or range of such payments may change The anniversary of the due date of the periodic principal and interest payment or range of such payments that immediately follows the occurrence of multiple payment ranges A scheduled balloon payment The lender must automatically terminate mortgage insurance or any functional equivalent under applicable law. o o o Even if the borrower may cancel the insurance earlier, use the date on which the lender must automatically terminate Mortgage Insurance coverage under applicable law. (Note: a decline in Mortgage Insurance premiums is not a triggering event. Generally, the automatic termination of Mortgage Insurance requires the corresponding periodic payment to be shown in its own column, unless doing so would exceed the four-column maximum. Where the automatic termination of Mortgage Insurance need not be shown in its own column, the column showing the next periodic payment or range of payments should show the periodic payment amount without Mortgage Insurance Compliance: TILA-RESPA Integrated Disclosures (TRID) Page 7 of 26 Version

8 The table cannot disclose more than four (4) separate periodic payments or ranges of payments. If more than four separate periodic payments, they should be disclosed as a single set in the last column except if there is an automatic termination of MI. o The automatic termination of mortgage insurance or any functional equivalent under applicable law shall require disclosure of an additional separate periodic payment or range of payments only if the total number of separate periodic payments or ranges of payments otherwise disclosed pursuant to this paragraph (c)(1) does not exceed three. Column headings: Use a sequence of whole years, counting from the due date of the initial payment. Examples o A two-column projected payments table might contain the headings years 1-7 and Years 8-30 if a triggering event occurs 85 months after the due date of the initial Periodic Payment. If a triggering event occurs in the middle of a year, use the next year in sequence as the heading for the subsequent column. o Assume a 30-year loan that requires Interest Only payments for the first 54 months from the due date of the initial Periodic Payment. The column heading for the initial Periodic Payment would be Years 1-5 and the column heading for the subsequent Periodic Payment would be Years 6-30 because the triggering event occurs during the 5th year of the loan. Field ID Name of Field Requirement (c)(2) (C)(3) Payment Calculation Show in one column the initial Periodic Payment (or range of payments if required) for each of Principal & Interest, Mortgage Insurance, and Estimated Escrow. Depending on the features of the loan, subsequent periodic payments also may be required to be disclosed. The Periodic Payment is the regularly scheduled payment of Principal & Interest, Mortgage Principal & Interest Insurance, and Estimated Escrow. Mortgage Insurance Estimated Escrow Amount can increase over time Estimate Total Monthly Payment Each separate periodic payment or range of payments shall be itemized as follows: Fixed Rate: Enter in each column the amount payable for the P&I payment include cents o To calculate the initial Periodic Payment, use the interest rate that will apply at closing, including any initial discounted or premium interest rate. Enter in each column the maximum amount of the monthly mortgage insurance premiums corresponding to the P&I payment, rounded to the nearest whole dollar o Includes any mortgage guarantee similarly to MI (VA Funding Fee and USDA Guarantee fee) o If no MI, enter 0 Enter in each column the amount payable into an escrow account to pay some or all of the charges that make up the Estimated Total Monthly Payment, as applicable, rounded to the nearest dollar, with a statement that the Amount can increase over time Enter in each column the total of the P&I payment, the Mortgage Insurance Payment, and any Estimated Escrow payment as the Estimated Total Monthly Payment. If MI and/or Escrow are disclosed round to the nearest whole dollar. If there is no MI or Escrow disclosed include cents. Interest Only Compliance: TILA-RESPA Integrated Disclosures (TRID) Page 8 of 26 Version

9 Enter the term Interest Only, if the loan is an IO Follow Adjustable Rate instructions below Adjustable Rate Enter in each column the amount payable for the P&I payment, include cents o If the interest rate at closing is not known, use the fully-indexed rate to determine the initial Periodic Payment (index + margin) Enter in each column the maximum and minimum P&I payments, rounded to the nearest whole dollar o The maximum amounts are determined by assuming that the interest rate in effect throughout the loan term is the maximum possible interest rate o The minimum amounts are determined by assuming that the interest rate in effect throughout the loan term is the minimum possible rate Enter in each column the maximum amount of the monthly mortgage insurance premiums corresponding to the P&I payment, rounded to the nearest whole dollar o Use the max/min interest rates that could apply such as through an interest rate cap. o Includes any mortgage guarantee similarly to MI (VA Funding Fee and USDA Guarantee fee) o If no MI, enter 0 Enter in each column the amount payable into an escrow account to pay some or all of the charges that make up the Estimated Total Monthly Payment, as applicable, rounded to the nearest whole dollar. This is then followed by a statement that the Amount can increase over time Enter in each column the total of the P&I payment, the Mortgage Insurance Payment, and any Estimated Escrow payment as the Estimated Total Monthly Payment, rounded to the nearest whole dollar if the MI and Estimated Escrow amounts are disclosed. If no MI or Escrow amount do not round. Estimated Escrow includes mortgage-related obligations other than premiums or other charges for any guarantee or insurance protecting the lender against borrower default or other credit loss, expressed as a monthly amount, even if no escrow account for the payment of some or any of such charges will be established. Mortgage-Related Obligations includes property taxes, fees and special assessments imposed by condominium, cooperative, or HOA s, ground rents, and leasehold payments; and charges that are required by the lender, including premiums or other charges for any guarantee or insurance protecting the lender against borrower default or other credit loss premiums or other charges for credit life, accident, health, or loss-of-income insurance written in connection with the transaction premiums or other charges for insurance against loss of or damage to property, or against liability arising out of the ownership or use of property, written in connection with a credit transaction charges or premiums paid for debt cancellation or debt suspension coverage written in Compliance: TILA-RESPA Integrated Disclosures (TRID) Page 9 of 26 Version

10 (c)(4) Estimate Taxes, Insurance & Assessments connection with a credit transaction, whether or not the coverage is insurance under applicable law Enter the sum of the amounts listed as Mortgage Insurance and Estimated Escrow as show above, rounded to the nearest whole dollar Verify the statement Amount can increase over time appears Check the applicable boxes to indicate if the estimated amount includes property taxes, homeowners insurance, and/or Other. If other, provide a description. Enter a YES or NO is the estimated amounts are escrowed (impounded) or not. Verify the statement See Section G on page 2 for escrowed property costs. You must pay for other property costs separately appears. Fixed Rate Example (c)(5) Calculation of Taxes and Insurance Estimated property taxes and homeowner s insurance are to reflect The taxable assessed value of the real property securing the transaction after consummation, including the value of any improvements on the property or to be constructed on the property, if known, whether or not such construction will be financed from the proceeds of the transaction, for property taxes; and The replacement costs of the property during the initial year after the transaction Costs at Closing Section Instructions to complete the Costs at Closing section on Page 1 Field ID Name of Field Requirement (d)(1) Estimated Closing Costs Estimated Closing Costs represents the total of all closing costs and lender credits as seen on Page 2. This should carry over and auto populate. (d)(2) Blank Space 1 -Enter the amount from J. Total Closing Costs disclosed on page 2 Blank Space 2 -Enter the amount disclosed in D. Total Loan Costs (A+B+C) on Page 2 Blank Space 3- Enter the amount disclosed in I Total Other Costs (E+F+G+H) on page 2 Blank Space 4 -Enter the amount of lender credits disclosed on page 2, J. Total Closing Costs Lender Credits Immediately followed by a statement See Page 2 for details. All amounts are rounded to the nearest whole dollar. Fixed Rate Example Purchase Transaction (no difference if adjustable) Estimated Cash to Close Estimated Cash to Close represents the total cash the borrower needs to close the loan, including total closing costs, down payment, seller credits etc. Blank Space 5 Enter the dollar amount of Estimated Cash to Close from the Calculating Cash to Close section on page 2, rounded to the nearest whole dollar Check the boxes as applicable Compliance: TILA-RESPA Integrated Disclosures (TRID) Page 10 of 26 Version

11 Verify the statement Includes Closing Costs. See Calculating Cash to Close on page 2 for details appears. Note: the check boxes from and to borrower will not appear on a purchase money transaction. Fixed Rate Example Purchase Transaction (no difference if adjustable) Estimated Cash to Close - Refinance Optional alternative table for transactions without a seller. For refinance transaction may alternatively disclose, using the label Cash to Close : Blank Space 5 Enter the sum total of the Loan Amount minus the Total Closing Costs (J), minus Estimated Total Payoffs and Payments, rounded to the nearest whole dollar. This should auto populate from Page 2 Calculating Cash to Close. Check the box indicated whether the disclosed estimated amount is due from or to the Borrower Verify the statement Includes Closing Costs. See Calculating Cash to Close on page 2 for details appears. Fixed Rate Example Refinance Transaction (no difference if adjustable) (e) Web site reference Verify the statement Visit for general information and tools appears at the bottom of Page 2. Compliance: TILA-RESPA Integrated Disclosures (TRID) Page 11 of 26 Version

12 LOAN ESTIMATE PAGE 2 Closing Cost Details Section Instructions to complete the Closing Cost Details section on Page 2 Loan costs sections represent all loan costs associated with the transaction. A good faith itemization of fees listed as loan costs must be labeled using terminology that describes each item. Points charged to reduce the interest rate must be the first item listed in the Origination Charges section. All other fees/services must be listed in alphabetical order. If State law requires additional disclosures, those additional disclosures must be on a document separate from, and not presented as part of, the Loan Estimate. Compliance: TILA-RESPA Integrated Disclosures (TRID) Page 12 of 26 Version

13 Field ID Name of Field Requirement (f)(1) Origination Charges An itemization of each amount, and a subtotal of all such amounts, that the borrower will pay to each lender and broker for the loan. The number of items disclosed cannot exceed 13 - addendums may not be used. If the lender has more than 13 charges, the remaining charges must be disclosed as an aggregate amount in the last line permitted, labeled Additional Charges. Enter all origination charges individually with a description of the fee, rounded to the nearest whole dollar and in alphabetical order o Includes charges paid to lender and broker o Do not include compensation paid by a lender to the mortgage broker Enter the points the borrower is paying to the lender to reduce the interest rate as both a percentage of the amount and a dollar amount, rounded to the nearest whole dollar and using the label % of Loan Amount (Points). Points are always listed first. o If points to reduce the interest rate are not paid, the fields must be blank Compensation paid directly by the borrower to the broker must be itemized individually but in alphabetical order rounded to the nearest whole dollar Loan level pricing adjustments charged by the lender as a fee to the borrower must be itemized individually but in alphabetical order rounded to the nearest whole dollar Fixed Rate Example Purchase Transaction (f)(2) Services You Cannot Shop For An itemization of each amount, and a subtotal of all such amounts, the borrower will pay for settlement services for which the borrower cannot shop and that are provided by persons other than the lender or broker. The number of items disclosed cannot exceed 13 - addendums may not be used. If the lender has more than 13 charges, the remaining charges must be disclosed as an aggregate amount in the last line permitted, labeled Additional Charges. The word Title must appear at the beginning of the fee description for any service that is a component of title insurance or is for conducting the closing. These may include, but are not limited to, examination and evaluation of title evidence to determine the insurability of the title being examined and what items to include or exclude in any title commitment and policy to be issued preparation and issuance of the title commitment or other document that discloses the status of title, identifies the conditions that must be met before the policy will be issued, and obligates the insurer to issue a policy of title insurance if such conditions are met resolution of title underwriting issues and taking steps needed to satisfy any conditions for the issuance of title insurance policies preparation and issuance of the title insurance policies, and payment of premiums for any lender s title insurance coverage The amount of the premium for the lender s title insurance coverage must be disclosed without any adjustment to the premium that might be made for the simultaneous purchase of an owner s title insurance policy. All fees must be rounded to the nearest whole dollar and appear in alphabetical order Compliance: TILA-RESPA Integrated Disclosures (TRID) Page 13 of 26 Version

14 (f)(3) Services You Can Shop For Examples of services the borrower cannot shop for may include, and are not limited to, appraisal fees, credit report fees, flood determination fee, VA or USDA guarantee fee, homeowner s association fees, lender s attorney fee, tax status search fee, third-party subordination fee, title-closing protection letter fee, title-lender s title insurance policy, and upfront MI An itemization of each amount, and a subtotal of all such amounts, the borrower will pay for settlement services for which the borrower can shop and that are provided by persons other than the lender or broker. The number of items disclosed cannot exceed 14 - addendums may be used. If the lender is not able to itemize all of the charges required to be disclosed in the number of lines provide, the remaining charges must be disclosed as follows: Label the last line permitted with an appropriate reference to an addendum and list the remaining items on the addendum in; or Disclose the remaining charges as an aggregate amount in the last line permitted labeled Additional Charges. The word Title must appear at the beginning of the fee description for any service that is a component of title insurance or is for conducting the closing. See examples under Services you cannot shop for above. All fees must be rounded to the nearest whole dollar and appear in alphabetical order Note: A lender permits an borrower to shop for an item if the lender permits the borrower to select the provider of that item, by providing a written settlement service provider list at time of the initial Loan Estimate. (f)(4) Total Loan Costs (A+B+C) Examples of services the borrower cannot shop for may include, and are not limited to, pest inspection fee, survey fee, title-closing agent fee, and title-closing protection letter fee. The sum of the subtotals disclosed under Origination Charges, Services You Cannot Shop For, and Services You Can shop For. Compliance: TILA-RESPA Integrated Disclosures (TRID) Page 14 of 26 Version

15 Closing Costs Details continued Instructions to complete the Other Costs section on Page 2 Other Costs represents all costs associated with the transaction that are in addition to the costs disclosed Loan Costs previously disclosed in this section. The items listed as loan costs pursuant must be labeled using terminology that describes each item. All fees in Taxes and Other Government Fees, Prepaids, Initial Escrow Payment at Closing sections must be listed in the order prescribed All other fees/services must be listed in alphabetical order Addendums to the forms are not permitted unless expressly stated. If not all fees can be itemized the remaining fees will be disclosed as an aggregate amount in the last line labeled Additional Charges Field ID Name of Field Requirement (g)(1) Taxes and Other Government Fees The amounts to be paid to State and local governments for taxes and other government fees, and the subtotal of all such amounts, as follows: Recording Fees and Other Taxes: Enter the sum of all recording fees and other government fees and taxes, except for transfer taxes paid by the borrower, rounded to the nearest whole dollar Transfer Taxes: Enter the sum of all transfer taxes paid by the borrower, rounded to the nearest whole dollar o Disclose only Transfer Taxes paid by the borrower. Who pays the transfer tax is based on applicable State or local law. For example: If a State law indicates a lien can attach to the borrower s acquired property if the charge is not paid, the amount is included as part of Transfer Taxes; If State or local law is unclear or does not specifically attribute the Compliance: TILA-RESPA Integrated Disclosures (TRID) Page 15 of 26 Version

16 o o amount to the seller or borrower, disclose the amount apportioned to the borrower using common practice in the locality of the property. Transfer taxes to be paid by the seller are not disclosed on the Loan Estimate as Transfer Taxes. Refer to the purchase contract to determine what the seller may be paying in transfer taxes on behalf of the borrower. If the purchase contract has not been received, the lender must use the apportionment of transfer taxes provided for by State or local law, or common practice. If an amount required to be disclosed is not charged to the borrower, leave the field(s) blank. All fees must be rounded to the nearest whole dollar and appear in alphabetical order (g)(2) Prepaids An itemization of the amounts to be paid by the borrower in advance of the first scheduled payment, and the subtotal of all such amounts, as follows: Homeowner s Insurance Premium ( months): Enter the number of months for which homeowner s insurance premiums are to be paid by the borrower at consummation and the total dollar amount to be paid at consummation, rounded to the nearest whole dollar. Mortgage Insurance Premium ( months): Enter the number of months for which mortgage insurance premiums are to be paid by the borrower at consummation and the total dollar amount to be paid by the borrower at consummation, rounded to the nearest whole dollar. Prepaid Interest ( per day for %): Enter the amount of prepaid interest to be paid per day, the number of days for which prepaid interest will be collected, the interest rate, and the total dollar amount to be paid by the borrower at consummation for such interest. Do not round Property Taxes ( months): Enter the number of months for which property taxes are to be paid by the borrower at consummation and the total dollar amount to be paid by the borrower at consummation, rounded to the nearest whole dollar If an amount is not charged to the borrower, leave field(s) blank. A maximum of three (3) additional items may be disclosed in this section and each additional item must be identified and include the applicable time period covered by the amount to be paid by the borrower at consummation and the total amount to be paid. All fees must be rounded to the nearest whole dollar and appear in alphabetical order, which the exception of Prepaid Interest which is not round (g)(3) Initial Escrow Payment at Closing An itemization of the amounts the borrower will be expected to place into a reserve or escrow account at consummation to be applied to recurring periodic charges, and the subtotal of all such amounts, as follows: Homeowner s Insurance ( per month for ) mo.: Enter the amount escrowed per month, the number of months covered by an escrowed amount collected at consummation, and the total amount to be paid into the escrow account by the borrower at consummation for homeowner s insurance premiums. Mortgage Insurance ( per month for ) mo.:. Enter the amount escrowed per month, the number of months covered by an escrowed amount collected at consummation, and the total amount to be paid into the escrow account by the borrower at consummation for mortgage insurance premiums Compliance: TILA-RESPA Integrated Disclosures (TRID) Page 16 of 26 Version

17 Property Taxes ( per month for ) mo.: Enter the amount escrowed per month, the number of months covered by an escrowed amount collected at consummation, and the total amount to be paid into the escrow account by the borrower at consummation for property taxes. If an amount is not charged to the borrower for any item, leave the fields(s) blank. All fees must appear in alphabetical order, individual monthly fees use cents, total round to nearest whole dollar A maximum of five (5) items may be disclosed and each such additional item must be identified with a descriptive label and include the applicable amount per month, the number of months collected at consummation, and the total amount to be paid. (g)(4) Other An itemization of any other amounts in connection with the transaction that the borrower is likely to pay or has contracted with a person other than the lender or broker to pay at closing and of which the lender is aware at the time of issuing the Loan Estimate, a descriptive label of each such amount, and the subtotal of all such amounts. The number of items disclosed cannot exceed five (5). Other includes for example: Commissions of real estate brokers or agents, Additional payments to the seller to purchase personal property pursuant to the contract of sale, Homeowner s association and condominium charges associated with the transfer of ownership, and Fees for inspections not required by the lender but paid by the borrower pursuant to the contract of sale. The word Title must appear at the beginning of the fee description for any service that is a component of title insurance. All fees must be rounded to the nearest whole dollar and appear in alphabetical order The parenthetical description (optional) shall appear at the end of the label for items disclosing any premiums paid for separate insurance, warranty, guarantee, or eventcoverage products (g)(5) Total Other Costs (E+F+G+H) The sum of the subtotals disclosed under Taxes and Government Fees, Prepaids, Initial Escrow Payment at Closing, and Other. All fees must be rounded to the nearest whole dollar (g)(6) Total Closing Costs D+I Lender Credits The component amounts and their sum, as follows: The sum of the amounts disclosed as loan costs and other costs D. Total Loan Costs (A+B+C) and I I. Total Other Costs (E+F+G+H) The amount of any lender credits, disclosed as a negative number with the label Lender Credits. o If there are no lender credits leave this field blank. o The lender should ensure that Lender Credits are sufficient to cover the estimated items the lender represented to the borrower as not being paid by the borrower at consummation, regardless of whether Compliance: TILA-RESPA Integrated Disclosures (TRID) Page 17 of 26 Version

18 such representations pertained to specific items. All fees must be rounded to the nearest whole dollar and appear in alphabetical order Closing Cost Details Calculating Cash to Close Instructions to complete the Calculating Cash to Close section on Page 2 Field ID Name of Field Requirement (h)(1) Calculating Cash to Close All Transactions: Enter the total amount of cash or other funds that must be provided by the borrower at consummation, with an itemization of that amount into the following component amounts. Total Closing Costs Enter the amount disclosed in J. Total Closing Costs section as a positive number rounded to the nearest whole dollar Closing Costs Financed Enter the amount of any closing costs to be paid out of loan proceeds, disclosed as a Compliance: TILA-RESPA Integrated Disclosures (TRID) Page 18 of 26 Version

19 negative number, rounded to the nearest whole dollar o If the amount is a positive number and the amount does not exceed the amount of the lender credit, then enter that amount as a negative number, rounded to the nearest whole dollar o If the amount is zero or negative number, then enter $0 Down Payment/ Funds from Borrower Purchase transaction: Enter the amount of the difference between the purchase price of the property and the principal amount of the loan, disclosed as a positive number, rounded to the nearest whole dollar o If the loan amount exceeds the purchase price, enter $0. All other transactions: Subtract the principal amount of the loan (excluding any amount disclosed as Closing Costs Financed (Paid form Your Loan Amount) from the total amount of all existing debt being satisfied in the transaction. o If the amount is positive, then enter this amount as the Down Payment, rounded to the nearest whole dollar o If the amount is negative or $0, then enter $0 as the Down Payment Deposit Purchase transaction: Enter the amount that is paid to the seller or held in trust or escrow by an attorney or other party under the terms of the agreement for the sale of the property, disclosed as a negative number, rounded to the nearest whole dollar All other transactions: Enter the amount of $0. Funds to Borrower Purchase Transaction: Enter $0 All other transaction: Subtract the principal amount of the debt (excluding any amount disclosed as Closing Costs Financed (Paid from Your Loan Amount) from the total of all existing debt being satisfied in the transaction. o If the amount is negative, the enter that amount as a positive number, rounded to the nearest whole dollar o If the amount is position or $0, enter $0 Seller Credits Enter the total amount the seller will pay for items included in the Loan Costs and Other Costs tables. Enter as a negative number, rounded to the nearest whole dollar Adjustments and Other Credits Enter the amount of all items in the Loan Costs and Other Costs tables that are paid by persons other than the broker, lender, borrower, or seller, together with any other amounts that are required to be paid by the borrower at closing pursuant to a purchase and sale contract, disclosed as a negative number, rounded to the nearest whole dollar Examples of items paid by personas other than the broker, lender, borrower or seller include: o Gifts from family members o Credits from developers or home builder to be applied to items in the Loan Costs, and Other Costs table Adjustments and other credits includes funds provided to the borrower from the proceeds of subordinate financings, local or State housing assistance grants, or other similar sources. Examples of amounts to be paid by the borrower at closing pursuant to the purchase contact include Compliance: TILA-RESPA Integrated Disclosures (TRID) Page 19 of 26 Version

20 o o o Charges for personal property to be acquired by the borrower Proration s for property taxes Proration s for homeowner s association dues Adjustments for credits are reduced by the amount of any such additional charges Estimated Cash to Close: The sum of the seven (7) other amounts disclosed under the Estimated Cash to Close table, rounded to the nearest whole dollar (h)(2) Optional alternative calculating cash to close table for refinance transactions The lender may use an alternative separate table for transactions that do not involve a seller (refinance transactions). The total amount of cash or other funds that must be provided by the borrower at consummation with an itemization of that amount into the following component amounts: Loan Amount: Enter the loan amount from Page 1 Total Closing Costs: Enter the amount from J. Total Closing Costs Estimated Total Payoffs and Payments: The total amount to be paid to third parties NOT disclosed as items in the Loan Costs or Other Costs tables, disclosed as a negative number. Examples of Payoffs and Payments not disclosed can include: o Payoffs of existing liens secured by the property such as mortgages, deeds, of trust, judgments that have attached to the property o Mechanics and materialmans liens o Local, State, and Federal tax liens o Payments of unsecured outstanding debts of the borrowers o Payments to third parties for outstanding debts of the borrower as required to be paid as a condition for the loan Estimated Cash to Close from or to Borrower: The sum total of the amounts disclosed as the Loan Amount, Total Closing Costs, and Payoffs and Payments, rounded to the nearest dollar. Select the appropriate check box is cash either due or owed by the borrower at consummation. Estimated Closing Costs Financed: The sum of Loan Amount and Payoffs and Payments, if the amount is greater than zero and less than or equal to the Total Closing Costs. Examples: o If the Loan Amount is $100,000, the Payoffs and Payments is-$80,000, and the Total Closing Costs is $10,000, then the Closing Costs Financed equals $10,000 o If the Loan Amount is $100,000, the Payoffs and Payments is-$95,000, and the Total Closing Costs is $10,000, then the Closing Costs Financed equals $5,000 o If the Loan Amount is $100,000, the Payoffs and Payments is-$110,000, and the Total Closing Costs is $10,000, then the Closing Costs Financed equals $0 Compliance: TILA-RESPA Integrated Disclosures (TRID) Page 20 of 26 Version

21 Closing Cost Details - continued Instructions to complete the Adjustable Payment (AP) Table on Page 2 If the periodic P&I payment may change after consummation but not based on an adjustment to the interest rate, or if the transaction is a seasonal payment product, an Adjustable Payment (AP) Table that contains the following information and satisfies the following requirements is required. Field ID Name of Field Requirement (i)(1) Interest Only Enter a YES if there are any interest only payments and the period they would apply Payments? (i)(2) Optional Payments Enter a No IMC does not permit optional payments, i.e., biweekly payments, and Payment Option ARMs. (i)(3) Step Payments? Enter a No IMC does not make or purchase Step loans. Compliance: TILA-RESPA Integrated Disclosures (TRID) Page 21 of 26 Version

22 (i)(4) (i)(5) Seasonal Payments? Monthly Principal and Interest Payments Enter a No IMC does not allow seasonal payments. First Change/Amount: Enter the number of the payment that may change, counting from the first periodic payment due after consummation, and the amount or range of the periodic principal payment and interest payment, rounded to the nearest whole dollar Subsequent Changes: Enter the frequency of the subsequent changes to the periodic payment. Maximum Payment: Enter the maximum payment that may be paid during the life of the loan, rounded to the nearest whole dollar, with the number of the first periodic P&I payment that can reach that amount. Instructions to complete the Adjustable Interest Rate (AIR) Table on Page 2 If the interest rate may increase after consummation, a separate table, the Adjustable Interest Rate (AIR) Table, that contains the following information and satisfies the following requirements is required (j)(1) Index + Margin If the interest rate may, enter the index upon which the adjustments to the interest rate are based and the margin that is added to the index to determine the interest rate. If the margin is a whole number truncate the decimal point. Examples 4.00% = 4% 4.5% = 4.50% Maximum is 3 decimal places (j)(2) Intentionally Left Blank (j)(3) Initial Interest Rate Enter the interest rate at consummation If the interest rate is a whole number truncate the decimal point. Examples 4.00% = 4% 4.5% = 4.50% Maximum is 3 decimal places (j)(4) Minimum/ Maximum Interest Rate Enter the minimum and maximum interest rates for the loan, after any introductory period expires If the interest rate is a whole number truncate the decimal point. Examples 4.00% = 4% 4.5% = 4.50% Maximum is 3 decimal places (j)(5) Change Frequency First Change: Enter the month when the interest rate after consummation may first change, calculated from the date interest for the first scheduled periodic payment begins to accrue Subsequent Changes: Enter the frequency of interest rate adjustments after the initial adjustment to the interest rate (j)(6) Limits on Interest Rate Changes First Change: Enter the maximum possible change for the first adjustment of the interest rate after consummation Subsequent Changes: Enter the maximum possible change for subsequent Compliance: TILA-RESPA Integrated Disclosures (TRID) Page 22 of 26 Version

23 adjustments of the interest rate after consummation If the change on interest rate is a whole number truncate the decimal point. Examples 4.00% = 4% 4.5% = 4.50% Maximum is 3 decimal places Compliance: TILA-RESPA Integrated Disclosures (TRID) Page 23 of 26 Version

24 LOAN ESTIMATE PAGE 3 Contact Information Section Instructions to complete the Contact Information section on Page 3 Field ID Name of Field Requirement (k)(1) LENDER NMLS/ LICENSE ID (k)(2) MORTGAGE BROKER NMLS/ LICENSE ID LOAN OFFICER NMLS/ LICENSE ID Lender Name and NMLS: Enter the name and NMLS Mortgage Broker Name and NMLS: If a wholesale transaction, then enter the name and NMLS If lender or the mortgage broker has not been assigned an NMLS ID, enter the license number or other unique identifier issued by the applicable jurisdiction or regulating body with which the lender or mortgage broker is licensed and/or registered, with the abbreviation for the State of the applicable jurisdiction or regulatory body stated before the word License. Enter the name and NMLSR ID of the individual loan officer and NMLS ID/License ID, of the lender and the mortgage broker, if any, who is the primary contact for the borrower. (k)(3) PHONE If lender or the mortgage broker has not been assigned an NMLS ID, enter the license number or other unique identifier issued by the applicable jurisdiction or regulating body with which the lender or mortgage broker is licensed and/or registered, with the abbreviation for the State of the applicable jurisdiction or regulatory body stated before the word License. Enter the address and telephone number of the loan officer Comparison Section Instructions to complete the Comparisons section on Page 3 Field ID Name of Field Requirement (l)(1) In 5 Years Enter the total principal, interest, mortgage insurance, and loan costs scheduled to be paid through the end of the 60th month after the due date of the first periodic payment, expressed as a dollar amount, along with the statement Total you will have paid in principal, interest, mortgage insurance, and loan costs Enter the principal scheduled to be paid through the end of the 60th month after the due date of the first periodic payment, expressed as a dollar amount, along with the Compliance: TILA-RESPA Integrated Disclosures (TRID) Page 24 of 26 Version

25 statement Principal you will have paid off. Example Fixed Rate Transaction Example IO ARM Transaction (l)(2) Annual Percentage Rate (APR) Enter the Annual Percentage Rate, using that term and the abbreviation APR and expressed as a percentage, and the following statement: Your costs over the loan term expressed as a rate. This is not your interest rate. If the APR is a whole number truncate the decimal point. Examples 4.00% = 4% 4.50% = 4.500% 4.555% = 4.555% Disclose up to three (3) decimal places (l)(3) Total Interest Percentage (TIP) Enter the total amount of interest that the borrower will pay over the life of the loan, expressed as a percentage of the loan amount, using the term Total Interest Percentage, the abbreviation TIP, and the statement The total amount of interest that you will pay over the loan term as a percentage of your loan amount. If the TIP is a whole number truncate the decimal point. Examples 4.00% = 4% 4.5% = 4.50% Maximum is 3 decimal places Other Considerations Section Compliance: TILA-RESPA Integrated Disclosures (TRID) Page 25 of 26 Version

26 Instructions to complete the Comparisons section on Page 3 Field ID Name of Field Requirement (m)(1) Appraisal Provides the appraisal disclosure pursuant to ECOA/Regulation B (m)(2) Assumption Provides a statement of whether a subsequent purchaser of the property may be permitted to assume the remaining loan obligation on its original terms. Example: (m)(3) Homeowner s Insurance Provides a statement that homeowner s insurance is required on the property and that the borrower may choose the insurance provider (m)(4) Late Payment Provides a statement detailing any charge that may be imposed for a late payment, stated as a dollar amount or percentage charge of the late payment amount, and the number of days that a payment must be late to trigger the late payment fee Enter the dollar amount or percentage and the number of days (m)(5) Refinance Provides the statement Refinancing this loan will depend on your future financial situation, the property value, and market conditions. You may not be able to refinance this loan. (m)(6) Servicing Provides a statement of whether the lender intends to service the loan or transfer the loan to another servicer. Check the applicable box: (m)(7) Liability After Foreclosure Refinance Transaction only: A brief statement that certain State law protections against liability for any deficiency after foreclosure may be lost, the potential consequences of the loss of such protections, and a statement that the applicable should consult an attorney for additional information. Instructions to complete the Confirm Receipt section on Page 3 Field ID Name of Field Requirement (n)(1) Signature Statement At the lender s option, signature line may be added to the form. If the signature line is added, following disclosure must appear above the signature line: By signing, you are only confirming that you have received this form. You do not have to accept this loan because you have signed or received this form. If no signature line is used following disclosure must appear under the heading Other Considerations required by section (m) above, labeled Loan Acceptance : You do not have to accept this loan because you have received this form or signed a loan application. Compliance: TILA-RESPA Integrated Disclosures (TRID) Page 26 of 26 Version