White Paper: Loan Estimate

Loan Estimate: Deep Dive

Commentary and Analysis

White Paper and Article

June 17, 2015

EXCERPTS

Punditocracy

Application

ARTICLES

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You may be interested in reading my recently published article, entitled "Loan Estimate: Deep Dive."

In this White Paper, I plan to take you solely through the Loan Estimate in considerable detail. I will discuss salient highlights of the Loan Estimate, though I caution you to realize that this review is not exhaustive or comprehensive, given that the TRID rule contains very complex disclosure requirements, far more involved, byzantine, elaborate, incisive, and potentially enigmatic than the compendiary features of it discussed herein.

This White Paper, consisting of 18 pages, is the third article of a four-part series.

In the first article, I discussed the mission of TILA-RESPA Integration and the Loan Estimate (LE).

The second article introduced and treated the numerous features of the Closing Disclosure (CD).

Each of the foregoing articles were accompanied by detailed tables to be used for certain itemized categories and action requirements.

The final and fourth article will provide an extensive analysis of the Closing Disclosure.

I would suggest that you read all the articles in this series in order to better understand the TILA-RESPA Integration Disclosure (TRID) rule promulgated by the Consumer Financial Protection Bureau (CFPB). The series is available in our Library .

The article is published in the June 2015 edition of National Mortgage Professional Magazine . A Free Subscription is available to our subscribers.

I hope you find this White Paper informative!

Regards,

Jonathan Foxx

President and Managing Director

EXCERPT

One of the reasons I have written this series is to cut through the information noise. My concern stems from the nearly profiteering stance of the flourishing punditry to opine on TRID. This approach to learning seems to have become the norm recently at conferences, conventions, webinars, seminars, lectures, and pricey city-to-city forums. Indeed, also, people with no real experience in directing regulatory compliance, though having some training background, seem to hang out their TRID webinar shingle. I view the latter as but shills for generating leads for their affiliated pundits.

EXCERPT

TRID formally does away with the catch-all, seventh information item. Six information items are needed to constitute an application. A creditor may provide a Loan Estimate without receiving all of the six items of information that comprise an "application" within the meaning of Regulation Z. But if it does this, the receipt of any of the missing items does not constitute a "changed circumstance" to justify a revised Loan Estimate.

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