TRID – Understanding the TILA-RESPA Integrated Disclosure (“TRID”) Volume 3

28 Jan

We will pass along a number of questions and clarifications of TRID every day for the next several days.

The information provided is for informational purposes only and should not be used or relied upon for any other purpose. This information is not intended nor should it be construed as providing legal advice. Tradition Title Agency does not guarantee, and assumes no responsibility for, the accuracy, timeliness, correctness, or completeness of the information. Always seek the advice of competent counsel with any questions you may have regarding any legal issue.

Volume 3
Are title endorsements placed on separate lines on Page 2 in Section C or do they roll-up to Lender’s Title Insurance?
The loan title fees will appear in either Section B or C depending on the circumstances*; however, roll-ups are not used on the Closing Disclosure (CD), only itemization. Therefore, endorsements will each appear on separate lines and will be listed starting with “Title -” and then a description of the endorsement. Remember, all fees will be shown in each section in alphabetical order.
* Loan title fees will be shown in Section B if the consumer is given the option to shop for title and they choose a title provider that is on the lender’s “Provider List” or if the provider is an affiliate (under the definition of affiliate) of the lender or mortgage broker. Loan title fees will appear in Section C if the consumer is permitted to shop and the chosen provider is not listed on the lender provider list (or is not an affiliate of the lender or mortgage broker).
Is it a requirement that the closing/settlement fee be itemized or can it continue to be shown by the roll-up method?
Roll-ups will no longer be permitted. Each individual fee must be itemized in the appropriate section in alphabetical order and begin with “Title -” and then the fee name.
Where are the buyer’s and seller’s signature lines on the Closing Disclosure (CD)?
The Rule does not require signature lines from either the buyer or the seller; however, if confirming receipt, the signature line must contain the promulgated wording. Many software providers are considering adding an additional page, but if the escrow or closing company uses the ALTA Settlement Statement in addition to the CD, signature lines are provided on the ALTA Settlement Statement with authorization language to proceed.

 

 

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