Mortgage Broker TRID FAQs
Here are some commonly asked questions with the TRID implementation.
Loan Estimate (LE)
The “Loan ID#” field is for the lender’s loan number, so for a wholesale transaction, it would have to be assigned by AFR if we are the lender. Per the regulation, if the broker provides the LE and at that time the lender is unknown, then the name and address of the lender is left blank. Brokers are expected per the rule to make a “good faith effort” to disclose the lender’s name and address. This same guidance applies to the loan number. If AFR has been identified on the LE, then AFR’s loan number for this loan would be disclosed on the LE.
AFR will allow the broker to provide the LE.
The first box “A. Origination Charges” only consists of items paid directly by the borrower to compensate the loan originator and lender, which would include the borrower-paid compensation but not lender-paid compensation. (Lender Paid Compensation is disclosed on the CD.)
Closing Disclosure (CD)
AFR will prepare the CD. AFR will collaborate closely with the settlement agent to ensure both parties approve the final product. (On purchase loans, the settlement agent will prepare the Seller’s CD and provide AFR with a copy.)
If AFR is disclosing the Closing Disclosure, we WILL require the borrower’s signature. AFR will disclose on all Wholesale transactions (WS, WD, TPO) and all Table Funder transactions (TF) and all Correspondent loans (C) where AFR is preparing the Closing package.
If the borrower has accepted eConsent, AFR will deliver the CD to the Borrower electronically. If the Borrower did not accept eConsent, AFR will provide the Client with the CD and a wet signature will be required by AFR. Please keep in mind, that we start counting from the date the borrower executed the CD.
Wholesale Clients will log into Loan Center; the CD Sent date will be provided in their pipeline view.