Impac Mortgage Wholesale TRID Process Flow

Transcription

1 Impac Mortgage Wholesale TRID Process Flow What You Need to Know about Impac Mortgage Wholesale s TILA-Respa Disclosure Process Steve Curry SVP Director of Wholesale Business Development Impac Mortgage Corp.

2 TRID Process Flow Stage One: Pre-Application Through Submission of the Loan to Impac Application "The Big 6" Initial LE Broker Processing Submission

3 Application Stage: The Big Six TILA-RESPA dictates that the borrower s loan application has been received when the following information is received (It is not necessarily the date that the 1003 is completed): 1. Borrower Name 2. Social Security Number 3. Property Address 4. Income 5. Estimated Property Value 6. Mortgage Loan Amount The borrower must be supplied a Loan Estimate within 3 business days of receipt of The Big Six Application Items

4 Initial Loan Estimate Impac Gives You Two Options for Delivering the Loan Estimate Impac Prepared Initial LE and SSP Broker Prepared Initial LE and SSP

5 Impac Prepared Initial Loan Estimate and SSP (Recommended) Process Overview Upload to Impac FNMA 3.2 File Impac Prepares LE/SSP Validate Broker Fees Upload to Impac Run DU/AUS or Upload LP/iDASL Re-Issue Credit Upload Processed Credit Package Register Product and Pricing Issue Initial LE and SSP within three Business Days of Upload Remaining Initial Disclosures Upload Requested Documents Big 6 Application Date Submit Loan to Underwriting

6 Impac Prepared Initial Loan Estimate and SSP (Recommended) 1. Upload 3.2 File to Encompass TPO and Create Loan Number 2. Re-Issue Credit and Register your Product and Pricing in TPO Encompass 3. Upload the Loan Submission Form, Impac Fee Review Worksheet, Purchase Contract (if obtained), SSPL and 1003 to the document folder and Submit to Underwriting 4. Impac will create an LE based off of the fee sheet or fees validated through LumenRMS (SmartGFE) and will send LE and initial disclosures to the borrower 3 days or less from the date of the Big 6 (Evidence of receipt is required in all cases)

7 Impac Prepared Initial Loan Estimate and SSP (Recommended) 5. If there is not enough AUS/income documentation/asset documentation/your broker disclosures in the file for the UW to do the initial UW, loan will be Un-submitted, but will appear in your TPO pipeline for further processing 6. Run DU/AUS in Encompass TPO or supply your own DU/LP/iDASL and upload income and asset documentation as well as your initial disclosures and then re-select Submit to Underwriting 7. Loan will be reviewed for completeness by Impac and then moved to UW

8 Impac Prepared Initial Loan Estimate and SSP Fee Review Worksheet Please complete ONLY the fee sections (no need to complete top section) Unless otherwise indicated, Impac will disclose the Title/Escrow Fees of their national provider and list them on the SSP After the SSP List is provided, the Borrower can choose their own title and escrow providers whose fees are listed on the initial CD

9 Completing the Initial LE on Your Own Process Overview Pre Big 6 Fee Review Complete Your LE, SSP, and Initial Disclosures Process and Submit Your Loan to Impac

10 Completing the Initial LE on Your Own: Pre Big 6 Fee Review Prior to receipt of the borrower application ( The Big Six ), Impac Mortgage can validate your loan fees to be charged in the transaction the following items to: [email protected] Impac Fee Review Worksheet Summary of Title and Escrow Fees from broker s chosen provider (if available) Impac validate fees with LoanEstimate (formerly SmartGFE) and will respond to brokers within 24 hours and advise them of any issues/corrections

11 Completing the Initial LE on Your Own: Fee Review Worksheet Prior to receiving the Big 6 Application Items, Impac will validate the fees you intend to use when completing your Initial Loan Estimate Complete form and to Loan.Estimate@ ImpacMail.com Please include a print out from your title/escrow provider verifying their fees on the transaction DO NOT Send any other forms, until time of full submission

12 Completing the Initial LE on Your Own 1. Once you obtain the Big Six Application Items, you will issue your initial Loan Estimate (LE) and SSP within 3 Business Days along with your other upfront disclosures 2. Upload 3.2 File to TPO Encompass, re-issue credit, register product and pricing, upload your fully processed loan with your LE, SSP, and all remaining disclosures to documents folder 3. Submit Loan to UW (Evidence of receipt is required in all cases) Impac has provided several tools on our website to help to ensure all LE s will be accepted. If a LE is not accepted the TRID rule does not permit Lenders to accept a new or revised LE.

13 Completing the Initial LE on Your Own We have provided several tools to help you complete and deliver your own Loan Estimate (LE). Please find the following resources: LE Quick Reference Guide An overview of what Impac Mortgage Corp. Requires on the LE Instructions to Complete the LE View an informational video about the Loan TRID Timing and Delivery View and informational video about TRID Timing and Delivery TRID Mailbox Rule TRID Tolerance Thresholds TILA Finance and Non-Finance Charges TRID Settlement Service Provider List (SSP List)

14 Ordering Your Appraisal Timeframe s for Appraisal Order from Impac s Appraisal Portal or the VA Appraisal Portal For Submissions with Impac Generated LE: Order upon e-receipt by borrower of LE, SSP and Lender Disclosures AND receipt of borrowers intent to proceed. If not digitally received, order 3 business days after LE and SSP have been mailed, AND receipt of borrower intent to proceed. For Submissions with Broker Generated LE: Order upon receipt of borrower signed LE or order 3 business days after LE and SSP have been mailed, AND receipt of borrower intent to proceed. (Evidence of receipt is required in all cases.)

15 TRID Process Flow Stage Two: Submission through Funding Revised LE Clear to Close Closing Disclosure Loan Documents Funding

16 Revised Loan Estimate Closing Docs cannot be signed within 7 Business Days after the initial Loan Estimate (LE)is placed in the mail or delivered; Electronically submit LE except where the borrower does not have access to ; You are generally bound to the Loan Estimate and may not issue revisions due technical errors, miscalculations, or underestimated charges Impac will deliver a revised LE, which must be re-disclosed within 3 business days of a valid change of circumstance If a loan has been submitted to Impac and the broker receives information to establish an increase in tolerance level, the 3 day window to issue a revised LE starts from the date the broker receives the information A revised LE may not be provided once a Closing Disclosure (CD)has been provided

17 New Tolerances

18 New Tolerances

19 New Tolerances (Continued) COC only permitted to increase fees specifically associated with the change. Nothing else may increase Impac may only charge more than the amount disclosed when the original estimate, or lack thereof, was based on the best information reasonably available at the time of the disclosure. (good faith analysis) Padding fees is not permitted. If service disclosed on the LE is not performed that amount must be removed from the total of estimated charges when calculating the 10% cumulative Affiliate includes fees paid to affiliates of lender or brokers

20 Clear-to-Close: Closing Disclosure Impac will deliver the Closing Disclosure upon the loan file receiving a Clear-to-Close and identification of a Closing Date. If the final approval CTC results in a valid change of circumstance, a final revised Loan Estimate will be delivered, with the Closing Disclosure to be delivered the next business day; The final revised LE must be provided to the borrower 4 days prior to loan docs and 1 day prior to the Closing Disclosure (CD) being completed; Impac will deliver the Closing Disclosure upon the loan file receiving a Clear-to-Close and identification of a Closing Date. If the final approval CTC results in a valid change of circumstance, a final revised Loan Estimate will be delivered, with the Closing Disclosure to be delivered the next business day.

21 Closing Disclosure Timing and Delivery Where Possible, Impac will electronically deliver the Closing Disclosure. Upon electronic acceptance, the Final Loan Documents will be issued after the 3 rd business day.

22 Clear-to-Close: Closing Disclosure Impac Mortgage Corp. will deliver all Loan Estimates (LE) and Closing Disclosures (CD) electronically except where the borrower does not have access to

23 TRID The Impac Wholesale Process Impac Mortgage Corp. Wholesale is dedicated to assisting and educating their broker partners with TRID. Should you have additional questions or would like a presentation for your office regarding Impac Mortgage Corp. s TRID requirements and resources, please do not hesitate to contact me for further assistance. We hope that these tools help to ensure all LE s will be accepted. If a LE is not accepted the TRID rule does not permit Lenders to accept a new or revised LE.

24 TRID The Impac Wholesale Process Questions? Only To Learn More at