I received an update yesterday from Wells Fargo, and as usual, they are getting in front of the change!  YEAH for them!  Here is what I received...PAY ATTENTION LOAN OFFICERS!

One more thing we can thank WALL ST for..

 However, are any of these REALLY bad ideas??


Only one I SEE, is that NOW, and I am getting clarification, we will have to disclose TWICE??  Arghh... 

Oh and NICE APR suggestion!  People still dont even know what the APR is??  Now, we can really call the Truth in Lending disclosure, the Truth & Confusion form!

For all of you who would like me to be specific..this MAY BE a "Lender overlay", but I doubt it!  More than likely if the lender you fund with hasn't published something similar, they will be following suit.  Wells Fargo tends to be a leader, not a follower!

 Now....

The Mortgage Disclosure Improvement Act, effective July 30, 2009, part of the Housing and Economic Recovery Act (HERA) of 2008, specifies new requirements for the disclosure portion of the loan application and fulfillment process. Highlights of these changes include:

Collection of Fees:  No fees, other than a bona fide and reasonable credit report fee, can be charged prior to the applicant's receipt of the initial Truth-In-Lending (TIL) disclosure.

New Business Day Definition: Saturdays are now considered a business day for purposes of disclosure receipt. Business days will include all calendar days except Sundays and federal holidays.

Timing of Disclosures: Early disclosures must still be provided no later than three business days after receipt of an application. Under the new rule, early disclosures must also be provided at least seven business days before closing/signing.

Early Disclosure: The initial Truth-in-Lending (TIL) disclosure is required to be provided to the borrower on both purchase and refinance transactions involving a borrower's principal or secondary dwelling.

APR Change: If the APR increases by more than 0.125 percentage points from the value last disclosed to the borrower, a corrected Truth in Lending (TIL) disclosure must be furnished to the borrower at least three business days before closing/signing.

Re-Disclosure Mailing Period: When corrected disclosures are mailed, the borrower is presumed to have received their corrected disclosures three business days after mailing.

Here is what WELLS FARGO said about THEIR view on HERA!

"Wells Fargo Wholesale Lending continues to evaluate the requirements set-forth by HERA. We are committed to keeping you informed of changes taking place in our industry and here at Wells Fargo. Look for more information over the coming weeks."

Much like the TAX CREDIT, I will wait and see...and if it happens it happens....it is what it is....do what you have to do....we are going to play them ONE DAY AT A TIME....oh, sorry for all the metaphors!  NOT!

I have heard Realtors,Consumers,Appraisers,The general pulic,TV,News Media, and others asking for more "transparency"...HUH?? How much more do we really need until we get a grip...and start asking the customer to accept some responsibility??  We already have 27 documents we have to have signed...now, we are going to have to have 12 more??  Sweet!  I can't wait!

Thank you?

 As always, I welcome ALL of your comments, questions, concerns and issues!

If you prefer, you can email me at Darin@osmwi.com, or call me at 608-592-2227

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