Are you ready for the October 1st TRID changes? If you do construction loans, there are a number of changes. The change that generated a lot of discussion in our recent TRID: All About Construction Loans webinar is disclosing inspection and handling fees, including draw fees. TRID 2.0 gives two options:
- If you collect these fees at or before closing, disclose them on your Loan Estimate and Closing Disclosure.
- If you collect these fees after closing, disclose them on an Addendum to the Loan Estimate and Closing Disclosure.
Treat any change like any other valid changed circumstance. Re-disclose within three business days of a valid changed circumstance to reset any tolerances.
Remember, disclose based on the best information available to you at that time. If you do so, you can go back to the borrower, even after closing, to collect a potential increase if the change is a result of a valid changed circumstance.
Check out our TRID: All About Construction Loans webinar to learn more about the upcoming construction loan changes in plain English!