Plus: Upcoming Lender Input Sessions
Plus: Upcoming Lender Input Sessions
TRID Disclosure Guidance
Plus: Lender Input Sessions Tomorrow

TRID Disclosure Guidance
We outlined three disclosure options for the Deferred Payment Loan (DPL) under TRID in November 2015. Due to lender feedback around system and LOS issues, as well as our Master Servicer’s ability to review multiple disclosure options, we will no longer require that lenders adopt Option 1 by April 1. You may continue to use any of the three disclosure options listed below. 
Please ensure that your loan meets the requirements of the option you select. Pay particular attention to the “1% fees charged to borrower” test if you use the partial exemption (Option 3). 
For questions regarding which option is best fits your company processes, or for general questions on disclosing on the DPL program, please contact Michael Peterson.
Option 1: TRID Disclosures
You charged a Loan Processing Fee (fee must be at least $10, but no more than $100). The loan was covered by TILA in addition to RESPA. 
Action: Provide the following TRID disclosures to U.S. Bank HFA Division:
  • Loan Estimate
  • Closing Disclosure
Option 2: RESPA Disclosures
You did not charge a loan processing fee and did not use the RESPA partial exemption (12 CFR §1026.3(h) and HUD 1024.5), the loan was not covered by TILA but was covered by RESPA. 
Action: Provide the following RESPA documents to U.S. Bank HFA Division:
  • Good Faith Estimate (GFE)
  • HUD 1
Option 3: Company Generated Disclosures
You used the partial exemption (12 CFR §1026.3(h) and HUD 1024.5), so the loan was not covered by TILA but was covered by RESPA. You ensured the loan met the 1% fee cap and no fees in excess of this were charged to the borrower. Eligible fees include recording, application, and homeownership counseling.
Action: Provide a set of disclosures to U.S. Bank HFA Division that includes the elements required by 12 CFR Part §1026.18 (Regulation Z).* We have developed a sample disclosure for optional use with loans that use the partial exemption.
*Finance charge, APR, Total of payments due, Security interest, and Assumption policy are all covered with a TIL. Itemization of amount financed, terms of repayment, and a reference to the loan contract (note) need to also be disclosed.
Reminder: Register for Tomorrow's Lender Input Session
Please come and provide your feedback on how Minnesota Housing is doing. Excellent?  Needs improvement? We want your opinion!
Register for one of the sessions below where we can dig deeper to develop solutions and program adjustments:
Operations Input Session with Minnesota Housing and U.S. Bank Operations
Tuesday, March 15 from 9:30–11:30 a.m.
Geared towards processors, underwriters, closers, shippers, and operations managers, and will focus on: 
  • Lender support at Minnesota Housing and U.S. Bank HFA Division
  • TRID compliance
  • Lender training
  • Topics chosen by participants
Origination and Production Input Session with Minnesota Housing
Tuesday, March 15 from 1:30-3:30 p.m.
Geared towards loan officers, production managers, and branch managers, and will focus on:
  • Feedback on our conventional products
  • Downpayment and closing cost loans
  • Lender support at Minnesota Housing and U.S. Bank HFA Division
  • Marketing opportunities
  • Topics chosen by participants
Refreshments will be served at both sessions. Validated parking is available at the Block 19 Municipal Parking Ramp (145 East 7th Street at the corner of Jackson and East 7th Streets across from the Metro Square Building). Register today!
Need a Minnesota Housing Refresher?
Training is not just for loan officers! Our Webinars are just as important for underwriters, processors, closers and post-closers. Visit the training web page for more details and register for these upcoming Webinars:
Questions?
Reach the Partner Solutions Team at 651.296.8215 or 800.710.8871 between 7:30 a.m. and 5:00 p.m. on business days.
400 Sibley Street, Suite 300 | Saint Paul, MN 55101 US
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