trid quick reference guide - cmg...
TRANSCRIPT
Revised January 26, 2016
TRID
TRID
QUICK REFERENCE GUIDE 10.3.2015
© 2015 CMG Financial, All Rights Reserved. CMG Financial is a registered trade name of CMG Mortgage, Inc., NMLS #1820 in most, but not all
states. CMG Mortgage, Inc. is an equal opportunity lender, licensed by the Department of Business Oversight under the California Residential
Mortgage Lending Act No. 4150025, Loans made or arranged pursuant to a California Finance Lenders Law license No. 6053674. Offer of credit is
subject to credit approval. For information about our company, please visit us at www.cmgfi.com. To verify our complete list of state licenses,
please visit www.nmlsconsumeraccess.org. For more information on State licenses, please visit http://www.cmgfi.com/corporate/licensing. Not
intended to serve as a business solicitation for residents in Massachusetts. For Wholesale Brokers and Select Partner Clients only.
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Contents TRID – Effective Date ..................................................................................................... 2
TRID – Definition of an Application ..................................................................................... 2
Important Definitions ..................................................................................................... 2
TRID – Creating New Loans ............................................................................................... 3
Create New Loan with an Application Dated on or after 10/3/2015 & Requesting an LE .................... 4
Creating New Loan with Applications Dated Prior to 10/3/2015 ................................................. 9
Transferred Loan ........................................................................................................ 12
Creating TBD Registration ............................................................................................. 15
Creating An AIO-All in One Registration ............................................................................. 19
Creating Quick Register to Advance Lock ........................................................................... 23
COC – Change of Circumstance ........................................................................................ 28
Ordering the Appraisal Using an Authorization Code ............................................................. 30
Generate the Closing Disclosure - CD ................................................................................ 31
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TRID – Effective Date TRID rules go into effect with applications taken or after 10/3/2015. The following loans are exempt from TRID rules:
1. Loans with application dates before 10/3/2015. 2. All In One Loans 3. HELOCs 4. Reverse Mortgages 5. Mortgages secured by a mobile home or dwelling not attached to real property
At CMG Financial, you will only need to concern yourself with the first two exemptions. We do not originate HELOCS, Reverse Mortgages or mortgages secured by a mobile home or dwelling not attached to real property. Applications on or after 10/3/2015, will be originated with the new TRID forms, Loan Estimate (LE) and Closing Disclosure (CD). This document is meant to walk you through the new technology.
TRID – Definition of an Application With the implementation of TRID the CFPB has redefined the application. The CFPB states that when
you have the following six pieced of information, that is considered to be an application and the clock
starts for disclosing.
1. The Consumer’s Name
2. The Consumer’s Income
3. The Consumer’s Social Security Number to obtain a credit report (or unique identifier if the
consumer does not have a social security number).
4. The Property Address
5. An Estimate of the Value of the Property
6. Loan Amount
Important Definitions Wholesale/Broker definitions. For Select Partners, please refer to the TRID Select Partner
Presentation.
General Business Days: Monday – Friday, excluding Saturday, Sunday and specific federal holidays.
Specific Business Days: Monday – Saturday excluding Sunday and specific federal holidays.
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TRID – Creating New Loans
On 10/3/2015, CMG’s website https://wt.cmgmortgage.com/DataTracWeb/Logon will be updated to include a new feature, ‘Create New Loan’. ‘Create New Loan’ is to be used as the starting point for all new loans. The ‘Create New Loan’ feature may be found under the Dashboard Tab.
After selecting the ‘Create New Loan’ option, you will be taken to the ‘New Loan’ screen. There you
will answer a series of questions to determine whether or not your loan is subject to the new TRID
Rules and the path that it will take during creation.
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Create New Loan with an Application Dated on or after 10/3/2015 & Requesting an LE
Once you have an application, these instruction will walk you through creating a new loan and
requesting an LE/disclosure package.
After signing into CMG’s website, from the Dashboard tab choose ‘Create New Loan’.
From the ‘New Loan’ screen, you will answer:
1. ‘Yes’ you have an application. Enter the application date or choose the date from the
calendar. For this scenario, the application date should be 10/3/2015 or after.
2. ‘Yes’ you have a property address
3. Submit, you will be taken to the ‘Create Loan and Generate Loan Estimate (LE)’ screen.
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From the ‘Create Loan and Generate Loan Estimate (LE)’ screen, Upload a 3.2 file or manually enter
the require fields to create the loan and generate the LE.
After uploading the 3.2 file, please review the screen and complete the fields that are not available
with the upload. The remaining fields should be intuitive.
Appraisal Information Section Clarification:
With your 3.2 upload or manual input of the ‘Create Loan and Generate Loan Estimate (LE) screen’,
CMG is gathering the information to create an LE and obtain a title, closing and accurate appraisal fee
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quote. You will be required to answer three items in the Appraisal Information section to complete the
quote.
NOTE: This section does not speak to the eTrac Appraisal ordering site. The information that we are
gathering here is for fee quote purposes only.
1. Final or Re inspection 1004D Required - From the dropdown choose ‘Yes’ or ‘No’.
2. Rush Fee – From the dropdown choose ‘Yes’ or ‘No’
3. Size (In Acres) – You will have 4 options to choose from.
After all of the information has been entered correctly, ‘Generate LE Request’ will appear green at the
bottom of the page. Click ‘Generate LE Request’.
If the ‘Generate LE Request’ field appears red, required items may have been missed. Please tab
through the fields or look for the item that may also be highlighted red. Once all fields are completed
correctly, the ‘Generate LE Request’ field will appear in green.
NOTE: Please do not use any punctuation in the fields when completing the form.
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After clicking on the ‘Generate LE Request’ you will receive the following message that confirms that
your creation was successful and it includes the new loan number.
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The newly created loan may be found in your pipeline under the Pipeline tab.
Once the new loan has been created, the loan may be locked. Find the loan in the ‘Registered’ section
of your pipeline, click on the loan number. From the next screen, scroll down to the bottom and find
the following action items.
Note: A new loan action item has been added to the menu of items available after clicking on the loan
number. ‘Upload FNMA 3.2’ may be used to upload an updated 3.2 file prior to submitting your loan to
CMG. Once loan has been submitted and status changed to Underwriter Received, this feature will no
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longer be available. All additional updates must be requested by sending an updated 1003 for review
by the underwriter.
Creating New Loan with Applications Dated Prior to 10/3/2015
NOTE: Friday 2/12/2016 will be the last day CMG will accept Pre-TRID transactions. All Pre-TRID
transactions must be submitted to the CMG Wholesale office no later than 2/12/2016. Loans with application
dates prior to October 3, 2015 will not be accepted after 2/12/2016 and will require that the borrower re-apply
and the loan will be subject to TRID rules.
All loans with applications dated prior to 10/3/2015, must close and fund by 3/31/2016.
Note: Construction loans are excluded from having to close by 3/31/2016
A New Loan may be created for loans with application dates prior to 10/3/2015 by following these
steps. Sign into CMG’s website, from the Dashboard tab choose ‘Create New Loan’.
From the ‘New Loan’ screen, you will answer:
1. ‘Yes’ you have an application. Enter the application date or choose the date from the
calendar.
2. ‘Yes’ you do have a property address
3. Submit, you will be taken to the ‘Create Loan ONLY (no LE will be generated)’ screen.
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From the Create Loan ONLY (No LE will be generated) Screen, you will need to complete the required
information. A 3.2 Upload is not available on this screen.
Once all of the fields have been entered, the ‘Registration’ field at the bottom of the page will appear
green. Click on ‘Register’ to create your TBD registration.
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If the ‘Register’ field appears red, required items may have been missed. Please tab through the fields
or look for the item that may also be highlighted red. Once all fields are completed correctly, the
‘Register’ field will appear in green.
NOTE: Please do not use any punctuation in the fields when completing the form.
After clicking ‘Register’ you will receive the following message that confirms that your creation was
successful and it includes the new loan number.
The newly created loan may be found in your pipeline under the Pipeline tab.
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Once the new loan has been created, the FNMA 3.2 file may be uploaded and loan locked. Find the
loan in the ‘Registered’ section of your pipeline, click on the loan number. From the next screen,
scroll down to the bottom and find the following action items.
Note: The Broker will be responsible for disclosing all up front disclosures to the borrower(s).
Transferred Loan
Transferred loans: A transferred loan is a loan where CMG did not prepare the initial Loan Estimate
(LE) within 3 general business days of receiving the application and the broker/borrower want CMG to
be the creditor on that particular transaction.
Effective on Monday, 2/1/2016, CMG will only allow transferred loans where the initial LE was
prepared in the broker’s name and no creditor/lender was identified on the LE.
Loans where the initial LE was prepared in another lender/creditor’s name are not eligible for transfer. A new loan application and applicable LE will be required (NEW)
Requirements:
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Expired Loan Estimates: Transaction where an LE (non-CMG LE) was prepared in the broker’s name and issued within 3 general business days of receiving the loan application. The borrower did NOT provide an Intent to Proceed (ITP) within 10 days of the LE being issued.
o CMG will accept that loan with a copy of the initial expired Broker LE (It must be a minimum of 11 days from the issue date) and a LOE from the loan officer stating that the Intent to Proceed (ITP) was never provided by the borrower(s).
Cancelled or Withdrawn loans: Transactions where an LE (non CMG LE) was prepared in the broker’s name and issued within 3 general business days of receiving the loan application. The borrower(s) DID provide an Intent to Proceed (ITP). The transaction is later withdrawn or cancelled by the borrower.
o CMG will accept that loan with a copy of the initial LE that was issued in the broker’s name within 3 business days of the application date and a LOE from the borrower that they wish to cancel their application with the initial investor/lender and want to proceed with an application with CMG Financial. The LOE must be dated and the CMG Loan Estimate must be requested within 2 business days form the date on the letter. The transfer letter does not need to include the name of the original lender. A Sample Copy of this letter may be found on the TRID Resource page in the Reference Material Section
Sign into CMG’s website, from the Dashboard tab choose ‘Create New Loan’.
From the ‘New Loan’ screen, you will answer:
1. ‘Yes’ you have an application. Enter the application date from the original application or
choose the date from the calendar.
2. ‘Yes’ you do have a property address
3. Submit
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After hitting submit you will be taken to the ‘Need More Info’ screen.
1. Answer whether or not you have a compliant LE. If the answer is No, you will need to have the
borrower reapply before submitted your loan to CMG.
2. Choose the status of the loan from the drop down.
3. Submit
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NOTE: When completing the ‘Create Loan and Generate LE’ screen, please consider the date of
the borrower’s written request expressing their desire to submit their application to CMG Financial
or denial letter as the application date.
Please refer to page 5 and follow the steps.
Creating TBD Registration
A TBD registration may be created by following these steps. Sign into CMG’s website, from the
Dashboard tab choose ‘Create New Loan’.
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From the ‘New Loan’ screen, you will answer:
4. ‘Yes’ you have an application. Enter the application date or choose the date from the
calendar.
5. ‘No’ you do not have a property address
6. Submit, you will be taken to the ‘Create Loan ONLY (no LE will be generated)’ screen.
From the Create Loan ONLY (No LE will be generated) Screen, you will need to complete the required
information. A 3.2 Upload is not available on this screen.
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Once all of the fields have been entered, the ‘Registration’ field at the bottom of the page will appear
green. Click on ‘Register’ to create your TBD registration.
If the ‘Register’ field appears red, required items may have been missed. Please tab through the fields
or look for the item that may also be highlighted red. Once all fields are completed correctly, the
‘Register’ field will appear in green.
NOTE: Please do not use any punctuation in the fields when completing the form.
After clicking ‘Register’ you will receive the following message that confirms that your creation was
successful and it includes the new loan number.
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The newly created loan may be found in your pipeline under the Pipeline tab.
TBD Next steps:
The LE/Disclosure package will not be created or sent to the borrower.
Once a property has been identified, within 2 business days you will need to notify your Account
Manager and provide him/her with the property address. The Account Manager will update the account
with the property address and remove the TBD from the program code. Once these updates have been
made you will be able to request the LE. The ‘Generate a Loan Estimate’ option can be found by
locating the loan in your pipeline, clicking on the loan number and scrolling down to the Loan Action
items.
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Creating An AIO-All in One Registration
The AIO-All In One program is exempt from TRID Rules. An AIO loan may be created following these
steps. Sign into CMG’s website, from the Dashboard tab choose ‘Create New Loan’.
From the ‘New Loan’ screen, you will answer:
1. ‘Yes’ you have an application. Enter the application date or choose the date from the
calendar.
2. ‘Yes’ you do have a property address.
3. ‘Yes’ this is an AIO loan.
4. Submit, you will be taken to the ‘Create Loan ONLY (no LE will be generated)’ screen.
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From the Create Loan ONLY (No LE will be generated) Screen, you will need to complete the required
information. A 3.2 Upload is not available on this screen.
Once all of the fields have been entered, the ‘Registration’ field at the bottom of the page will appear
green. Click on ‘Register’ to create your TBD registration.
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If the ‘Register’ field appears red, required items may have been missed. Please tab through the fields
or look for the item that may also be highlighted red. Once all fields are completed correctly, the
‘Register’ field will appear in green.
NOTE: Please do not use any punctuation in the fields when completing the form.
After clicking ‘Register’ you will receive the following message that confirms that your creation was
successful and it includes the new loan number.
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The newly created loan may be found in your pipeline under the Pipeline tab.
Once the new loan has been created, the FNMA 3.2 file may be uploaded and loan locked. Find the
loan in the ‘Registered’ section of your pipeline, click on the loan number. From the next screen,
scroll down to the bottom and find the following action items.
NOTE: The AIO – All In One program is TRID exempt, it is the broker’s responsibility to send out
the early disclosures to the borrower(s).
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Creating Quick Register to Advance Lock
On those rare occasions when you do not have the six pieces of information that define an
application or you have a complete application and need to quickly lock the loan, we have that
covered.
A Quick Register to Advance Lock registration may be created by following these steps. Sign into
CMG’s website, from the Dashboard tab choose ‘Create New Loan’.
From the ‘New Loan’ screen, you will answer:
1. ‘No’ you do not have an application.
2. ‘Yes’ you do have a property address
3. ‘Yes’ you would like to “Quick Register to Advance Lock’
4. Submit - you will be taken to the ‘Create Loan ONLY (no LE will be generated)’ screen
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From the Create Loan ONLY (No LE will be generated) Screen, you will need to complete the required
information. A 3.2 Upload is not available on this screen.
Once all of the fields have been entered, the ‘Registration’ field at the bottom of the page will appear
green. Click on ‘Register’ to create your new loan.
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If the ‘Register’ field appears red, required items may have been missed. Please tab through the fields
or look for the item that may also be highlighted red. Once all fields are completed correctly, the
‘Register’ field will appear in green.
NOTE: Please do not use any punctuation in the fields when completing the form.
After clicking ‘Register’ you will receive the following message that confirms that your creation was
successful and it includes the new loan number.
The newly created loan may be found in your pipeline under the Pipeline tab.
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Search for the loan within the pipeline. Once found, click on the loan number. This will open the loan
and appropriate action items. To lock the loan, choose the ‘Lock’ action item and complete the
required fields to lock the loan.
Note: An LE has not been generated. The LE must be requested within two ‘General Business
Days’ of the loan being locked or risk the lock being cancelled. Automated email reminders will be
sent to the contacts provided when loan created.
The LE may be requested by accessing the loan within the pipeline. Click on the loan number, scroll
down to the action items and choose, ‘Generate Loan Estimate’.
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After choosing ‘Generate Loan Estimate’, the ‘Create Loan and Generate Loan Estimate (LE)’ screen
will open. From here you will upload your FNMA 3.2 file or manually complete the fields to create your
LE. Refer to page 5 of this document and follow the steps.
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COC – Change of Circumstance
You can notify CMG of a COC – Change of Circumstance by submitting an online request. Any fee
increase or new fee incurred by the broker that will be charged to the borrower must be reported to
CMG at the time that you are aware of the fee. The COC action items will be available until the loan is
cleared to close. The COC option can be found by clicking on the loan number or action item to the far
right of the loan number.
After clicking on the loan number, the following screen will open and under the Loan Action section
you will find the Broker COC Request.
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By clicking on the action item to the far right hand side of the screen, the following screen will open
and you will find the Broker COC Request under the action items.
After opening either action item, you will be taken to the COC screen. Please enter any new or
updated fees as they incur, provide instructions and hit submit. CMG will be notified of the fee change
or update and process accordingly.
Please note that ALL changes to loan amounts, program/product, appraised value, sales price and
appraisal inspections will be processed by CMG once the underwriter has reviewed and approved.
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Ordering the Appraisal Using an Authorization Code
At the time that CMG generates the LE, we will also create the authorization code that is needed to
order the appraisal via the eTrac Appraisal ordering site. This code will be emailed to the email
address or addresses provided at the time that the LE was requested. This authorization code will also
be placed in the ‘Notes’ tab inside of the loan for future reference.
The email will be sent from [email protected] and the subject line will be Global DMS Code and
reference your CMG loan number. See below for a sample of the email that will be sent.
The authorization code must be entered into the ‘Authorization Code’ field inside of the eTrac
appraisal ordering site when placing the order.
Note: The appraisal cannot not be ordered until the a primary borrower has opened/received the
LE and he/she has indicated their Intent to Proceed.
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Generate the Closing Disclosure - CD
Once the underwriter has placed the “Approved” loan in CTC status, the ‘Closing Disclosure (CD) Order
Request’ will be an available action items inside of the loan. From the pipeline screen, find the loan,
click on the loan number. After the loan opens, scroll to the bottom, there you will find the ‘Closing
Disclosure (CD) Order Request’ action item. Click on the action item to open the Closing Disclosure
(CD).
Complete the required information within the online Closing Disclosure to schedule the loan for closing
and request the Closing Disclosure (CD). Most of the information will be completed on this screen as
the information is gathered during the approval process.