Does anyone ever get assignments where the client has gotten there copy 3 days in advance. What happened to the new law that went into effect in Oct. last year?
Yes, I’ve had most borrowers say they rec’d the Closing Doc 3 days prior.
All clients should see their numbers 3 days in advance, IF they originated their loan process after October 1, 2015. If the paperwork was started prior to Oct 1, 2015, the old rule applies and you should still see the old HUD and TIL not the new ALTA and 5 page Closing doc in your package. If there is a question about it, as always, contact title or loan officer.
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My take on this situation…
I am not the title company quality control department - if they want me to be they can pay me accordingly; but until then, it’s my feeling that if I get the assignment with agreed fee and confirmation, I will proceed on the belief that everyone before me has done their job as it should have been done, when it should have been done. It’s not my concern if they did or did not get their disclosures 3 days in advance. My only concern is getting the docs printed out, executed properly, notarized and returned…I have no involvement in SS/TC compliance with the CFPB.
JMO
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Most of the time, yes. But last week got docs late from title company. Only had time to print and run out the door with no time to review. Got to the appointment late. Borrower had not been given anything with figures and was unaware that there was over $900 due and this title company wouldn’t take a personal check over $500. Screw them. I would love to know who to report such bad behavior on the part of the title company. Seems like they are breaking some rules or law.
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“J” - was it a refi? Arrangements can be made to wire funds during the 3-day rescission period. I’d also question if borrower truly had not seen anything prior or at the least been told funds would be due at the table. That was one pitiful loan officer who dropped the ball on that one.
As for reporting? Possibly the regulatory agency of the state where the title company is licensed? Also, I’m sure CFPB has a reporting site - since they were the ones who came up with the 3-day advance notice requirement to begin with.
Also, I always make time to review…I don’t print and fly; too much can happen, like discovering later that I got the wrong docs (or get half package for my borrower and half for another), docs didn’t print properly, typos, etc etc…and in your case, funds due.
Did you end up with a signing or did the borrower not sign after seeing this? Just curious.
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Never run off with late dox without review and confirmation with borrower… even if it means arriving at signing late. Not your fault.
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To J, in a perfect world, we would have time to go through docs. But I mostly have to.print and run. For most part all my clients have seen closing disclosure.
Most have received the day before, via email. I’m not certain, but I thought I read somewhere that if CD is mailed to them, they need to have it 3 days prior, but email is 24 hours, which has been the case 99.9 % of the time with all my borrowers.
I don’t accept “last minute” signings at all. This is my business and my integrity is on the line. I won’t accept any signing in less than 24 hours. Last minute or rush signings are the result of someone not doing their job properly or within the time required so making up for their incompetence is not my job. Yes, it means less business but I promise quality work and need the time to review the documents and confirm the appointment with the borrower(s). In many cases, I also need to print out directions to the signing address since I recently moved to another area and am not familiar with all the streets yet.
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The CFPB regulation states that borrowers are to receive the CD at least three days before the closing of their mortgage. No matter the manner of delivery, they are to receive it 3 days prior.
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