Effective
immediately, the attached 2 forms are required as indicated below:
·
Required
on all files. This is the form the borrower will use to acknowledge
receipt of the GFE provided by the Loan Officer. This form must be
submitted with the GFE and the rest of the loan file to setup. Form must
be filled out completely. Variations of this form may be accepted,
provided the subject matter of the originator provided form contains all
relevant information
GFE
– Change in Circumstance Acknowledgement:
·
Required
when the GFE is redisclosed to the borrower due to an acceptable “change in
circumstance”, as described by RESPA (see below). Form must be filled out
completely.
Changed
Circumstances include:
·
Acts
of God
·
Information
particular to the borrower or transaction that was relied on in providing the
GFE and that changes or is found to be inaccurate after the GFE has been
provided, which information may include information about the credit quality of
the borrower, the amount of the loan, the estimated value of the property, or
any other information that was used in providing the GFE.
·
New
information particular to the borrower or transaction that was not relied on in
providing the GFE.
·
Other
circumstances that are particular to the borrower or
transaction, including boundary disputes, the need for flood insurance, or
environmental problems.
·
None
of the information collected by the loan originator prior to issuing the GFE
may later become the basis for a changed circumstance upon which a loan
originator may offer a revised GFE, unless the loan originator can demonstrate
that there was a change in the particular information or that it was
inaccurate, or that the loan originator did not rely on the information issuing
the GFE.
A
Changed Circumstance does NOT include:
·
Changing
the borrower’s name
·
Changing
the borrower’s monthly income
·
Changing
the subject property address
·
Changing
the estimated value of the property
·
Changing
the mortgage loan amount * (see below for specific example)
·
Any
information in the credit report generated prior to issuance of the GFE, unless
the information has changed or found to be inaccurate
·
Changed
in Market price (yield)
Here
are various examples regarding issuance of a revised GFE:
·
Circumstances affecting settlement costs - If the changed circumstance
results in an increase in settlement costs at closing and exceeds the
tolerances, a revised GFE can be given within 3 business days of receiving the
information sufficient to establish the changed circumstance. If a
revised GFE is given, the increase in charges must be limited to only those
charges where the changed circumstance resulted in the higher charge.
·
Circumstances affecting the loan – If there is a change to the borrower’s eligibility
for the specific loan terms identified in the original GFE, the originator may
provide a revised GFE to the borrower. However, it must be issued within
3 business days of receiving the information sufficient to establish the
changed circumstance.
·
* Borrower-requested changes – If a borrower requested a
change resulting in a change to the terms of the loan or the settlement charges
(such as a change in mortgage loan amount), an originator may provide a revised
GFE within 3 business days of the borrower’s request. If the GFE is not
provided within 3 days of the change request
·
Changes and terms dependent upon interest rate – If the interest rate is not
locked or a lock has expired, the charge or credit for the interest rate, the
adjusted origination charges, per diem interest and loan terms related to the
interest rate may change. Once the borrower does lock (or re-lock) the
rate, a new GFE must be provided reflecting the rate dependent charges and
terms. All other terms and charges not affected by the rate must remain
the same. ** If a revised GFE is not provided to the borrower
within 3 days of the loan being locked, then the fees on the initial GFE may
not be changed.
·
New Home Purchases – If the loan is for a new home purchase and the
settlement is expected to be beyond 60 calendar days from the GFE issuance, the
originator may provide the GFE with a separate disclosure (clear and
conspicuous) stating that any time up until the 60 calendar days before the
closing, a revised GFE may be issued. If this is not done, the originator
cannot issue a revised GFE.
We will
allow some leeway, as this is a new announcement. However, when a file is
received in Setup without the required Acknowledgement of Receipt (or
acceptable broker variation thereof), Setup will respond to the Loan Originator
that it must be included on all submissions henceforth and will include a copy
of this email
Thank you!
J. Whitney Barth
VP Operations
Gateway Mortgage Group LLC
972.908.3390 x101 p
918.392.8336 f
02/19/2010