TILA RESPA Integrated Disclosures (TRID) Sun West Policies

TILA RESPA Integrated Disclosures (TRID) Sun West Policies

TILA RESPA Integrated Disclosures (TRID) Sun West Policies Sun West Mortgage Company, Inc. (NMLS ID 3277) is licensed by the Department of Corporations under the California Residential Mortgage Lending Act and holds a California Finance Lenders Law License (#6030119) and a BRE Real Estate Corporation License (#00793885). Refer to www.swmc.com to see where SWMC is a licensed lender. In all states, the principal licensed office of Sun West Mortgage Company, Inc. is 18000, Studebaker Road, Suite 200, Cerritos, CA 90703; Toll Free: (800) 453 7884. Programs, rates, fees, costs, terms and conditions are subject to change without notice. Sun West Mortgage Company, Inc. NMLS ID 3277. All Rights Reserved. DISCLAIMER This presentation is current as of today. The content in this presentation is for general information purposes only. This presentation does not represent legal interpretation, guidance or advice from Sun West Mortgage Company, Inc. While efforts have been made to ensure accuracy, this presentation is not a substitute for the rule. Only the rule and its Official Interpretations can provide complete and definitive information regarding requirements. This document does not bind Sun West and does not create any rights, benefits, or defenses, substantive or procedural, that are enforceable by any party in any manner. You are advised to consult your own compliance staff or attorney regarding your specific residential mortgage lending questions or situation to ensure your compliance with applicable laws and regulations. Sun West Mortgage Company, Inc.

NMLS ID 3277. All Rights Reserved. ABOUT SUN WEST Sun West Mortgage Company, Inc. was established in 1980 with the purpose of helping people realize the American dream of homeownership. We strive to offer our customers and partners not only the most competitive mortgage rates, but also one of the most comprehensive lines of mortgage products in the industry. Today, our operation is comprised of a solid network of branches across the nation, covering retail, wholesale, correspondent and warehouse channels. We are a well-established Fannie Mae, Freddie Mac, Ginnie Mae, FHA, VA, and USDA approved originator, offering our customers and partners a full-service facility for their mortgage needs and a

complete selection of mortgage options, including Conventional, FHA, VA, USDA, Reverse Mortgages (HECM), and Jumbo Mortgages. We are a lender with extensive lending experience and expertise, built through our own in-house market research and analysis. Our mission is to expand our business by focusing more on service and quality. Thank you for choosing Sun West Mortgage! Sun West Mortgage Company, Inc. NMLS ID 3277. All Rights Reserved. AGENDA Introduction SWMC Policy On Wholesale Loans LE Request Screen CD Preparation SWMC Policy On Correspondent / Warehouse Loans

Q&A Sun West Mortgage Company, Inc. NMLS ID 3277. All Rights Reserved. INTRODUCTION TRID is applicable on applications received on or after October 03, 2015. Initial Truth-in Lending disclosure(TIL) and RESPA Good Faith Estimate (GFE) combined into new Loan Estimate (LE) Final Truth-in-Lending disclosure and RESPA HUD-1 combined into new Closing Disclosure(CD) Existing process of requiring GFE and TIL will be followed for all applications taken before October 03, 2015. General business days for disclosure are defined as the days on which SWMC offices are open to the public for carrying out substantially all of its business functions. Saturday, Sunday and all legal federal holidays are not included in general business days. Specific business days are defined as all calendar days except Sundays and federal holidays. Sun West Mortgage Company, Inc. NMLS ID 3277. All Rights Reserved.

APPLICATION Application date is the date on which a loan originator has received the below six set of information in any form (Ex - written or electronic format, and includes a written record of an oral application). 6 ITEMS THAT TRIGGER APPLICATION A Address L Loan Amount I Income E Estimated Value of the Property N Name S Social Security Number An application is considered complete when all six items are provided. The timeline for disclosures begins on that date. Sun West Mortgage Company, Inc. NMLS ID 3277. All Rights Reserved. TRID DISCLOSURES - OVERVIEW A Loan Estimate is to be disclosed to the borrower within 3 general business days of receiving the application and 7 specific business days prior to consummation.

A revised Loan Estimate is to be disclosed within 3 general business days of the occurrence of a change in circumstance and should be received by borrower 4 specific business days prior to consummation. The TRID rule prohibits fees, except a bona fide and reasonable credit report fee, before the consumer has received the Loan Estimate and indicated to the creditor an intent to proceed. A Closing Disclosure is to be delivered to the borrower 3 specific business days before consummation. Sun West Mortgage Company, Inc. NMLS ID 3277. All Rights Reserved. TRID DISCLOSURES - OVERVIEW

Know Before You Owe toolkit and Written List of Service Providers is to be provided to the borrower within 3 general business days of application. Though a broker may be involved in a transaction, it is creditors responsibility to ensure that disclosures are provided within compliance requirement. Settlement agent is responsible for providing the seller copy of the Closing Disclosure. Note The 7 business day waiting period required by MDIA will still apply. Please register for any of our upcoming webinar on TRID Overview for Wholesale and Correspondent Partners to elaborately understand all the changes under the TRID rule. Sun West Mortgage Company, Inc. NMLS ID 3277. All Rights Reserved. PRE APPROVAL A Loan Estimate is not required to be disclosed on pre approval requests where subject property for purchase has not been

identified by the borrower. Loan Estimate should only be disclosed once subject property is identified. If subject property i.e. the sixth set of information is identified on or after 3rd Oct 2015, TRID rule will be applicable on these loans. Effective 09/24/2015, SWMC will not accept any pre approval requests where a Good Faith Estimate (GFE) has already been disclosed without the subject property address being identified. Sun West Mortgage Company, Inc. NMLS ID 3277. All Rights Reserved. SWMC POLICY - WHOLESALE LOANS SWMC will accept wholesale loan submission in following ways: Broker discloses Loan Estimate with a blank lender name and loan id Broker requests SWMC to disclose Loan Estimate

Broker must opt for either of two options, while submitting any loan to SWMC. Irrespective of the option opted, broker is responsible for all other federal and state specific disclosures. Broker is prohibited from issuing a Loan Estimate in the name of SWMC or with a SWMC loan number. SWMC reserves the right to cancel the loan in Sun Soft on the 3 rd business day of application if SWMC has not been requested to disclose LE or provided an LE disclosed by the broker by the end of 2nd business day. A soft copy of any Loan Estimate or Closing Disclosure that is disclosed by SWMC will

also be sent to the broker loan officer and processor. Sun West Mortgage Company, Inc. NMLS ID 3277. All Rights Reserved. SWMC POLICY - WHOLESALE LOANS Effective all applications on or after Oct 3rd 2015, SWMC has eliminated the charge of $945 underwriting fee for all wholesale loans. No Lender Fee adjustment will continue to be applicable to all programs except FHA Streamlines, VA IRRRLs, & HECMs. SWMC will require acknowledgement of receipt from all consumers in case of rescindable transactions or only from primary borrower in case of nonrescindable transactions for reducing the additional 3 days mailbox rule that is applicable in case of a revised LE disclosure.

Once LE is disclosed, change in compensation plan will not be allowed unless it is documented that such change is requested by borrower. LE Helpdesk is set up with availability from Monday through Friday, 6 AM through 6 PM PST to assist brokers with any questions. Helpdesk phone number is (866) 473-5711. Sun West Mortgage Company, Inc. NMLS ID 3277. All Rights Reserved. WHOLESALE LOANS: BROKER DISCLOSES LE If a Broker is not aware of the creditor to which loan will be submitted, Broker should disclose LE without creditor name and loan id. In accordance with the rule, if the broker is aware on the loan being submitted to SWMC, the broker must request SWMC to disclose LE.

Broker disclosed LE must be provided to SWMC along with loan submission. Written List of Service Providers and Know Before You Owe toolkit that was disclosed to borrower within 3 days of a loan application must be provided to SWMC. SWMC will completely review the broker disclosed LE and written list of service providers. SWMC will only proceed with the loan if the disclosures are acceptable and in compliance with the TRID rule. Sun West Mortgage Company, Inc. NMLS ID 3277. All Rights Reserved. WHOLESALE LOANS: BROKER REQUESTS SWMC TO DISCLOSE LE

Once broker creates a loan in SunSoft, he will get an option to Request LE on the loan creation confirmation screen. The same button will also be constantly available on the left hand side of the screen above the Submit to Lender button. This option will redirect broker to LE request screen. Broker must authorize SWMC to disclose LE & certify that the data provided is accurate to the best information available to broker. Application date must be the date when six set of information is received by broker. Broker should upload 1003 supporting application date. Broker must request SWMC to disclose LE within one business day of application.

Sun West Mortgage Company, Inc. NMLS ID 3277. All Rights Reserved. WHOLESALE LOANS: BROKER REQUESTS SWMC TO DISCLOSE LE (Continued..) Appropriate Loan Type & Loan Purpose must be selected. Borrowers FICO Score must be provided along with supporting credit report. Borrowers email address is not a mandatory requirement however, email address will help towards timely closing of loan. If an e-mail address of borrower(s) is provided, all applicable disclosures will be sent electronically to the borrower(s).

We urge all our brokers to provide us the required details and documents for the disclosures to be sent electronically which will greatly help towards enhancing the loan closing turn around time. Sun West Mortgage Company, Inc. NMLS ID 3277. All Rights Reserved. WHOLESALE LOANS: BROKER REQUESTS SWMC TO DISCLOSE LE (Continued..) Broker must select appropriate compensation plan & if Borrower Paid compensation is selected, loan origination fees must be provided Broker must provide the Title Quote & Fee Worksheet to support the title charges & escrow amounts.

Broker should provide with Credit Report Fess & estimated Monthly Taxes & Homeowners insurance amounts. Sun West Mortgage Company, Inc. NMLS ID 3277. All Rights Reserved. WHOLESALE LOANS: BROKER REQUESTS SWMC TO DISCLOSE LE (Continued..) Broker should provide additional information regarding subject property Sun West Mortgage Company, Inc. NMLS ID 3277. All Rights Reserved. WHOLESALE LOANS: BROKER REQUESTS SWMC TO DISCLOSE LE (Continued..) Following is the consolidated list of information or documents that SWMC would require from the broker to disclose the Loan Estimate

Application Date Uniform Residential Loan Application (1003) Loan Type and Purpose Borrower(s) FICO with credit report

Borrower(s) e-mail address for disclosures to be sent electronically Origination Compensation type Compensation amount in case of Borrower paid compensation Processing fee amount in case of Borrower paid compensation Total Title fees w/o Owners Title Insurance fees Owners Title Insurance fees (If applicable) Title Quote (If available) Applicable Credit Report fees Monthly Taxes and Homeowners Insurance Property Type Additional property related details Whether the loan is a NY CEMA loan for refinance transactions in the state of NY Written List of service providers to be disclosed to the borrower Sun West Mortgage Company, Inc. NMLS ID 3277. All Rights Reserved. WHOLESALE LOANS: LE REQUEST TIMELINE Sun West Mortgage Company, Inc. NMLS ID 3277. All Rights Reserved.

WHOLESALE LOANS: WRITTEN LIST OF SERVICE PROVIDERS On loans with initial LE disclosed by broker, broker is responsible for disclosing Written List of Service Providers (WLSP) to borrower within three business days of application. On loans with initial LE requested to be disclosed by SWMC, broker should provide SWMC with the list of service providers that is to be disclosed to the borrower. If a broker does not provide SWMC the WLSP along with initial LE disclosure request, SWMC reserves the right to cancel the loan as incomplete application on the second day of application Sun West Mortgage Company, Inc.

NMLS ID 3277. All Rights Reserved. WHOLESALE LOANS: WRITTEN LIST OF SERVICE PROVIDERS WLSP should include: i. ii. iii. iv. Name of service Name of service provider Contact details of service provider Estimate of charges is optional WLSP must be disclosed for below services: i. Title Services ii. Survey (If required on loan/ must in NJ & TX)

iii. Pest Inspection (If required on loan/ must on VA loan with subject in moderate to high TIP zone) SWMC does not have any affiliates. If service provider used on loan is affiliated with the broker, those fees will be subject to a 0% tolerance. It is responsibility of broker to inform SWMC at [email protected] whenever broker has any new affiliate. Sun West Mortgage Company, Inc. NMLS ID 3277. All Rights Reserved. WHOLESALE LOANS: INTENT TO PROCEED Borrower signing & dating the LE is not an ITOP. Borrower should e-sign or wet sign the ITOP form. Apart from credit report fee, no fee can be imposed or collected from borrower until

the borrower provides ITOP. Broker will be able to order any service on the loan only after three specific business days from the initial LE sent date and a subsequent receipt of ITOP from borrower. In case any service is to be ordered prior to completion of the three specific business days from the initial LE sent date, the broker will have to provide a borrower signed LE to SWMC and a ITOP that is received post the signing of the Loan Estimate. Only exception to this is credit report, which can be pulled prior to receipt of ITOP. The broker may use their own ITOP, use the SWMC sample ITOP under Print Docs or document with an e-mail received from any borrower on the loan. In case ITOP is documented through an e-mail sent by the borrower, SWMC reserves the right to verify the authenticity of the e-mail provided. Sun West Mortgage Company, Inc. NMLS ID 3277. All Rights Reserved. WHOLESALE LOANS: CLOSING DISCLOSURE

SWMC will disclose Closing Disclosure after the loan is cleared to close and loan is locked. Closing Disclosure by the settlement agent to the consumer is not acceptable In case of purchase transaction, SWMC will require the settlement agent to provide the seller copy of the CD to the seller. SWMC will require the Final CD to be signed by all parties involved in the transaction. The waiver of cooling period for a bona-fide financial emergency would be very rare and at SWMCs discretion.

SWMC will require acknowledgement of receipt from all consumers in case of rescindable transactions or only from primary borrower in case of non-rescindable transactions for reducing the 3 days mailbox rule that is applicable in case of a CD disclosure. CD Helpdesk is set up with availability from Monday through Friday, 6 AM through 6 PM PST to assist brokers and settlement agents with any questions. Helpdesk phone number is (866) 543-0384. Sun West Mortgage Company, Inc. NMLS ID 3277. All Rights Reserved. ADDITIONAL BROKER RESPONSIBILITIES The broker is responsible for notifying SWMC within 24 hours, once the broker is aware of a change in circumstance or addition of a fee. Broker can communicate change in circumstance requests by sending an e-mail to [email protected] Once the revised Loan Estimate or Closing Disclosure is sent to the borrower, it is the responsibility of the broker to contact the applicable recipients to

immediately open the e-disclosure so that the additional 3 days mailbox rule applicable can be reduced. The broker will monitor that one of the borrower has received the LE and should then contact the borrower to obtain their ITOP. The broker is prohibited from ordering the appraisal prior to borrower receiving the LE and providing a ITOP, even if the broker is paying for the appraisal fee upfront with the intent to collect the fees at closing. Sun West Mortgage Company, Inc. NMLS ID 3277. All Rights Reserved. SWMC POLICY ON CORRESPONDENT & WAREHOUSE LOANS SWMC will do a thorough and complete review of the Loan Estimate submitted for compliance and accuracy. SWMC will require appropriate change circumstance documentation in case of any re-disclosure of Loan Estimate or Closing Disclosure to reset baselines for a change in circumstance. SWMC will review the Closing Disclosure submitted for compliance and accuracy. SWMC will require signatures of all parties involved on the Final CD. SWMC will require copy of seller CD if it is provided separately in purchase

transactions. SWMC will require all disclosures under TRID rule and will continue to require all disclosures that are to be provided under the current federal and state specific rules Sun West Mortgage Company, Inc. NMLS ID 3277. All Rights Reserved. SWMC POLICY ON CORRESPONDENT & WAREHOUSE LOANS If a waiting period is waived on a loan due to bona-fide financial emergency, it will be at SWMCs discretion to purchase the loan. On loans where closing documents are drawn by SWMC, SWMC requires the lenders to ensure compliance with the initial and final closing disclosure. SWMC may prepare the final closing disclosure on request of the correspondent lender if the required information has been provided to SWMC. Evidence of the calculations for the lenders tolerance cures must be provided. Any post closing revised CDs, if applicable, must be provided. If variance/cure is due to be paid to the borrower, evidence of payment should be provided prior to purchase. SWMC reserves the right to issue a repurchase request if any discrepancies

are identified by SWMC or its investors after the loan is purchased by SWMC. Sun West Mortgage Company, Inc. NMLS ID 3277. All Rights Reserved. QUESTIONS ? Sun West Mortgage Company, Inc. NMLS ID 3277. All Rights Reserved. THANK YOU SWMC is here to assist you in adopting this change. If you have any questions, please write to us at [email protected] You may also visit the Dedicated Regulatory Implementation Website: http://www.consumerfinance.gov/regulatory-implementation/tila-respa eRegulations Tool: http://www.consumerfinance.gov/eregulations Sun West Mortgage Company, Inc. NMLS ID 3277. All Rights Reserved.

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