1. It is important to be aware of the primary differences between the disclosures and disclosure
process Pre-TRID and Post-TRID. Below is an easy to read grid showing those differences,
effective 10/3/2015. Please do not hesitate to contact a HomeStreet Bank Loan Officer to ask
detailed questions about how TRID affects you and your clients.
BEFORE TRID AFTER TRID
A Loan Application is defined as:
• Applicants’ name(s)
• Social Security Number(s)
• Loan Amount
• Income
• Property Address
• Estimated Property Value
• Any “other information deemed
necessary by the lender”
A Loan Application is defined as:
• Applicants’ name(s)
• Social Security Number(s)
• Loan Amount
• Income
• Property Address
• Estimated Property Value
The Change? The provision of “Other information deemed necessary by the lender” is no
longer allowed, making for a more consistent application experience regardless of lender.
Initial Disclosure Forms
Lender must provide the initial GFE and
TIL within 3 business days of application.
Initial Disclosure Forms
Lender must provide the Loan Estimate (LE) within 3 business days of application.
The Change? A single form, the Loan Estimate, replaces both the GFE and TIL.
Cash to Close Disclosure
The estimate of “Cash to Close” is not
disclosed on the GFE or any other official
loan documents at this point in the process.
Cash to Close Disclosure
The new LE includes a Closing Cost Details page of itemized and categorized settlement
costs in an easy-to-read, alphabetical format. It also clearly states the estimated amount
of cash needed for closing in multiple places.
The Change? The new LE clearly discloses the Cash to Close information to the client earlier
on in the process than before.
Settlement Charges
The settlement costs are bundled on the GFE,
including the loan fees and title charges.
Settlement Charges
All charges, including loan fees and title charges are itemized on the new LE.
The Change? Origination fees and settlement costs have to be itemized for ease of understanding.
Allowable Tolerances
A 10% variance is allowed for the estimate of
those fees which a borrower cannot shop for,
such as appraisal, credit report, etc. before
new disclosures are triggered.
Allowable Tolerances
There is zero tolerance for disclosure of fees for services the borrower is not able to choose:
appraisal fee, credit report, flood determination, HOA cert, tax service or any other fee for
a service required by the lender.
The Change? Lenders are held to a higher standard to quote accurate fees in good
faith. Inaccurate fee quotes can slow down the process or cause closing delays. It is in
the best interest of the borrower and agent to provide clear and accurate information at
application in order to assist the lender with providing accurate estimates of these fees.
Timing of Closing
If APR is out of tolerance by more than
0.125%, a re-disclosed TIL is to be issued
and 3 business days need to pass before
closing docs can be drawn.
Timing of Closing
The borrower must receive the Closing Disclosure (CD) at least 3 business days before Loan
Signing. If information changes, a Revised CD must be provided. If one of these changes is
movement in the APR of 0.125% or greater, change in Loan Product, or addition/removal of
a Prepayment Penalty, a 3-day waiting period may apply.
The Change? Any transaction covered by TRID requires a 3-day waiting period after the CD
is received by the borrower, regardless of whether there is an APR change. If a Revised CD
is triggered by one of the changes mentioned above, then a new 3-day waiting period is
also triggered along with the new Revised CD.
HUD-1 Preparation
The settlement agent is responsible for
preparing the HUD-1 statement.
Closing Disclosure Preparation
Under TRID, the lender is held responsible for the accuracy of the borrower’s CD, regardless
of who prepares it.
The Change? HomeStreet Bank will prepare the borrower’s CD, allowing the settlement
agent to prepare only the seller’s CD.
HUD-1 Disclosure
The HUD-1 contains bundled settlement
charges in two columns to indicate who
is paying the fee.
Closing Disclosure
The CD itemizes the settlement charges in 5 columns to show who is paying and when each
fee is paid.
The Change? The CD has been expanded to provide much more detailed information
for the borrower. This provides them a place to see ALL of the fees associated with their
transaction in one place.