Q1: Can the new TRID Disclosures be used before the effective date?
A1: The TRID Rule is effective for applications taken on or after August 1, 2015. Early compliance is not permitted so the disclosures cannot be used on live loans prior to August 1st. Application dated prior to August 1st must close using the current documents (GFE, TIL and HUD).
Q2: What loan types are not subject to the TRID Rule?
A2: TRID does not apply to the following loan types:
· Home Equity Lines of Credit (HELOCs)
· Reverse Mortgages
· Mortgages secured by a Mobile Home or dwelling not attached to real property
**This means these loan types are closed using the current documents (GFE, TIL and HUD).
Q3. Does the registration of a loan trigger the application date?
A3. No, loan registration does not trigger the application date. The application date is based on the day the loan officer signs the application. The borrower must sign on/after that date. If the loan application was taken over the phone, by mail, etc. then we wouldn't required the borrower's signature--in those cases the LO signature is sufficient.