Corrected Closing Disclosure - Encompass Experience

Transcription

Click to edit Master title style
Closing, Shipping & Funding with Ease
THE MORTGAGE PROCESS
Pam Faulkner – Manager, Advisory Consultants – Ellie Mae
Patrick Kenny – VP Business Operations & Services Manager – EverBank
Karen Whitcomb – Technical Support Manager – Ellie Mae
Juliet Overton – Sr. Compliance Analyst – Ellie Mae
Rebecca Frisbie – Product Manager – Ellie Mae
©2015 Ellie Mae. All rights reserved.
Safe Harbor
This presentation may contain forward-looking statements under the safe
harbor provisions under The Private Securities Litigation Reform Act of
1995. These forward-looking statements may include the company’s
ability to enhance the features and functionality of the Encompass
software, the timing of the introduction and acceptance of additional
services and the timing of new product launches. Additional risks and
uncertainties related to the company’s business are discussed in the
company’s Securities and Exchange Commission filings, including but not
limited to the to the final prospectus relating to its initial public offering
[and the company’s most recent Quarterly Report on Form 10-Q]. Unless
otherwise required by applicable laws, the company undertakes no
obligation to update or revise any forward-looking statements, whether
as a result of new information, future events or otherwise.
Agenda
• Overview – Pam Faulkner – Ellie Mae
• Client Perspective – Patrick Kenny - EverBank
• Tips for Efficient Closing, Shipping & Funding– Karen
Whitcomb – Ellie Mae
• Closing How-To – Pam Faulkner – Ellie Mae
• More on RESPA-TILA Requirements– Juliet Overton
• Compliant Closing Docs– Rebecca Frisbie – Ellie Mae
EverBank
Pat Kenny
VP – Business Operations Support
& Services Director
About My Company – use for guest presenters
•
EverBank
•
Banking & Financial Services
•
Headquarter in Jacksonville, FL
•
Ellie Mae client since 2011
Best Practices
• EverBank’s Experience & Best Practices with Encompass
>
Implemented ULDD changes in phased approach
>
Identified & analyzed data deficiencies in loan delivery
>
>
EverBank CMO process allowed us to implement 50+ Encompass data
enhancements in 2014
Utilization of UAT testing and Automation testing of Encompass to
ensure accurate delivery of changes
Recent Enhancements
• Home Ownership Counseling Provider
>
Enhanced the quality of the data provided
>
Significantly reduced the application time by several minutes
Recent Enhancements
• Transmittal Summary
>
Enhanced the required fields for completion of Approval milestone to
align with ULDD
>
Implemented a hardstop to ensure required data is complete
>
Limited field characters to a max of 60 in order to meet Fannie Mae
guidelines for Condos
Recent Enhancements
• Appraisal Delivery Alert
>
Enhanced process to determine the Appraisal Delivery Date on loans
prior to closing in Encompass
>
Implemented an alert in Encompass for the “Appraisal Sent to
Customer” field
>
Ensured the most efficient and accurate record of the “Appraisal Sent to
Customer” data for loan delivery and compliance
Recent Enhancements
• Plan Code and Loan Program Persona Access
>
Convert specific fields i.e. (Last Rate Set Date, Lock Plan Code, Lender’s
Loan Product Code) to “Read Only” and restrict the access of the Loan
program field through the lock request screen on all loans that are
floating an interest rate
>
Implementation of this process has increased efficiency and reduced
financial risk
Recent Enhancements
• GMI Mapping to 1003
Application
>
Enhancement to allow
each individual choice
of “information not
provided” for race, sex,
and ethnicity to map to
the 1003
Recent Enhancements
• Encompass Test Automation
>
Efficient end to end testing of loan origination process
>
Reduced our testing time by 55% vs manual tester
>
We were able to receive instant feedback on data errors found through
functional testing
>
Provided us with more time for defect analysis and data quality review
Tips for Efficient Closing, Shipping & Funding
Karen Whitcomb
Technical Support Manager
Docs & Compliance
Closing Efficiencies
• Use a “Closing” Input Form
Template
>
>
>
>
>
>
>
>
>
>
>
>
>
>
>
>
Borrower Info Vesting
Closing Vendor Info
Closing RegZ
Property Information
2010 HUD-1 Page 1
2010 HUD-1 Page 2
2010 HUD-1 Page 3
Aggregate Escrow Account
Closing Conditions
State Specific Disclosure Info
1003 Page 1
1003 Page 2
1003 Page 3
FHA Management*
VA Management*
USDA Management*
*As applicable
Funding Worksheet
• Math done easy
>
Net Funding – Use your Template
Funding Worksheet
Funding Worksheet
Funding Worksheet
• Credits Due Borrower
>
HUD-1 Page 1 Button
Funding Worksheet
Funding Worksheet
Shipping Details
•
Information at your fingertips
Closing How-To
Pamela Faulkner
Manager, Advisory Consultants
Ellie Mae
Input Form Sets
• To create a list of input forms that will apply with your loan
type or simply with your loan template, you will simply follow
the example below:
Shipping Details
• Next proceed to the section for Loan Templates and select
Input Form Sets
• You may create new sets by clicking the New icon, creating a
name for your new set and then move your Input forms from
the Left to the Right to place them in the order you wish to
use.
Funding Templates
• To create your own funding template, you would access
settings and click on Secondary Setup
Funding Templates
• Click on Funding Templates.
• Click on the new icon and provide a name for your template.
• Next proceed to the check boxes and check those that you
will deduct from your funds at the time of disbursement.
• **Hint….remember the seller can pay fees too so you want
to check both if it’s possible there may be a seller paid fee on
the HUD-1 Page 2 Screen.**
More on RESPA-TILA Requirements
Juliet Overton
Sr. Compliance Analyst
Ellie Mae
Closing in the New World of RESPA/TILA
• Significant changes from RESPA-TILA will impact your
Closing Process. Including:
1. Advance Review of the Closing Disclosure
2. Last Minute material changes that can delay
the closing; e.g. increase in closing cost or
Loan amount.
3. Lender representatives
attending more Closings.
• Creditors are now responsible for
generating and delivering the
Closing Disclosure to the
buyer/consumer. In purchase
transactions Settlement agents
still retain the responsibility to
provide the closing disclosure to
the Seller.
• Closing Disclosure must be received by each consumer no
later than 3 specific Business Days before consummation.
Business Days related to the closing disclosure are federal
specific calendar days except Sunday and actual federal
Holidays.
• If a Creditor or Settlement Agent
does not provide the Closing
Disclosure in person, the
consumer is considered to have
received it 3 Business days after
delivered or placed in mail.
3
•
If the APR or the Loan Product
becomes inaccurate or a
Prepayment Penalty gets added
after a Closing Disclosure is
provided to a consumer:
>
A corrected Closing Disclosure must be
received by a consumer at least 3
business days prior to consummation.
>
If a corrected Closing Disclosure is
provided to a consumer other than “In
Person” it is presumed to be received 3
business days after it is provided.
>
The earliest closing date would be six
days after the corrected Closing
Disclosure is provided to a consumer
• In rescindable transactions,
the Closing Disclosure
MUST
be delivered separately
to each consumer who
has the right to rescind.
Closing Disclosure Timing Requirements – Non
Material Change Circumstances
•
Issue: Waiting Period for Consummation after Corrected Closing Disclosure based
•
Reg:1026.19(f)(2)(i)
•
TIME PERIOD / TYPE OF DAYS: No Waiting Period. Closing can occur any time after
Corrected Closing Disclosure are received by the consumer.
•
Method for Counting Days: Waiting period may be required if Corrected Closing
Disclosure is not provided in person.
•
Background: If Closing Disclosure becomes inaccurate before consummation, creditor
shall provide Corrected Closing Disclosure reflecting any changed terms to consumer so
consumer receives Corrected Closing Disclosure at or before consummation. Creditor
shall permit consumer to inspect Corrected Closing Disclosure, completed to set forth
those items that are known to creditor at time of inspection, during business day
immediately preceding consummation, but creditor may omit from inspection items
related only to seller’s transaction.
on Non-Material Change Circumstances
Closing Disclosure Timing Requirements – Changes
After Consummation
•
Issue: Delivery of Corrected Closing Disclosure based upon Changes After
Consummation
•
Reg:1026.19(f)(2)(iii)
•
TIME PERIOD / TYPE OF DAYS: Within 30 calendar days after consummation, deliver
Corrected Closing Disclosure no later than 30 calendar days after receiving information.
•
Method for Counting Days: Count the day the information regarding inaccuracy
received as Day 1. Deliver or mail Corrected Closing Disclosure before the end of the
thirty calendar days after.
•
Background: If during 30-day period following consummation, an event in connection
with settlement occurs that causes Closing Disclosure to become inaccurate, and
inaccuracy results in change to an amount actually paid by consumer, Creditor
shall deliver or place in mail Corrected Closing Disclosure not later than 30 calendar
days after receiving information sufficient to establish event.
Closing Disclosure Timing Requirements – Clerical
Errors
•
Issue: Delivery of Corrected Closing Disclosure After Consummation due to Clerical
Errors
•
Reg:1026.19(f)(2)(iv)
•
TIME PERIOD / TYPE OF DAYS: Within 60 calendar days after consummation.
Deliver Corrected Closing Disclosure
•
Method for Counting Days: Count the day the information regarding the changed
circumstance is received as Day 1. Deliver or mail revised Loan Estimate before the end
of the sixtieth day after consummation.
•
Background: If Closing Disclosure contains non-numeric clerical errors, Creditor must
deliver or place Corrected Disclosure in mail no later than 60 calendar days after
consummation. An error is considered clerical if it does not affect a numerical
disclosure, LE or CD requirements. If Closing Disclosure identifies incorrect settlement
service provider as payment recipient, Creditor to deliver or place in the mail corrected
disclosures reflecting corrected non-numeric disclosure no later than 60 days after
consummation. If disclosure lists wrong property address, error is not clerical.
Closing Disclosure Timing Requirements – Variance
•
Issue: Refund and Deliver Corrected Closing Disclosure if Variance found After
Consummation
•
Reg:1026.19(f)(2)(v); 1026.19(f)(1); 1026.19(e)(3)(i); 1029.19(e)(3)(ii) and
1026.19(e)(1)(i)
•
TIME PERIOD / TYPE OF DAYS: Within 60 calendar days after consummation.
Refund to customer and Deliver Corrected Closing Disclosure
•
Method for Counting Days: Deliver or mail the refund and Corrected Closing
Disclosure before the end of the sixtieth day after consummation.
•
Background: If amounts paid by consumer exceed variance, Creditor must refund
excess to consumer no later than 60 days after consummation. Creditor must deliver or
place in mail Corrected Closing Disclosure reflecting refund no later than 60 days after
consummation
Compliant Closing Docs
Rebecca Frisbie
Product Manager
Ellie Mae
RESPA/TILA – Pre-Closing
• Coming in 15.1
>
EDS customers will be able to “eDisclose” the
Closing Disclosure to fulfill 3 day prior to
consummation requirement via new Pre-Closing
order type.
• Pre-Closing
>
>
>
>
Closing Disclosure will
be the only form
Can add additional
forms via Encompass
or within EDS form
selection
EDS Settings
Closing EDS/ECS
Audits
RESPA/TILA – Pre-Closing
• Pre-Closing
>
>
Add existing standard forms
to the Pre-Closing package
Track in Disclosure Tracking
Tool
RESPA/TILA – Pre-Closing, con’t.
•
Via the Order Docs icon
>
>
Select Order type
Select applicable borrower pair
RESPA/TILA – Forms
•
Doc Engine
generating the new
forms
>
>
>
Print Menu
eDisclosure (LE only)
Closing Docs (CD
only)
• 2015 Migrating all
Standard Forms
>
>
>
Faster Document
Updates
Encompass hot update
not required
Increase speed of
package delivery
RESPA/TILA – New LE/CD Ripple Effect
•
Other Form Impact
>
>
>
Generic (ex. Right to Cancel)
Disclosure (state & federal)
Include references to:
o
o
o
o
o
>
GFE
TIL
Good Faith Estimate
Itemization
Settlement Statement
…within the body of the forms
• Disclosures made obsolete with the new rule
We’re on it!
Highlight Changes on Redraw
• Investor Selection will
highlight all forms
required to prepare for
sale to that Investor
>
Feature Introduced in 14.2
Client was looking for a way to
quickly find all Investor
required forms for loan that
they were selling after closing.

Corrected Closing Disclosure - Encompass Experience

Transcription

Similar documents

FURY erupted yesterday after it emerged an artist was given

NEXTREND DESIGN

TRID Technology Implementation

Lecturer: Physics Requirements: An M.Sc degree in Physics. At least

be in your new home before the new year!

Mae Browning`s 100th Birthday

DUST A SIDE

stepping out beside the usk