How does DocMagic handle the disclosure of Total Closing Costs on the Closing Disclosure?

  • Total Closing Costs at Closing (J) which is located in K03 of the Summaries of Transaction includes only closing costs paid by the borrower at closing and is reduced by any general lender credits.
  • Total Closing Costs (J) in the Cash to Close Table on the Closing Disclosure includes borrower-paid closing costs paid both at and before closing and is reduced by any general lender credits
  • J. Total Closing Costs (Borrower-Paid)on page 2 of the Closing Disclosure includes charges paid by the borrower at and before closing and reduced by lender credits.

Some of my loan costs are not appearing on the Loan Estimate, but they do appear on the Closing Disclosure.

Please double check that you are assigning an appropriate "TRID Section" to each fee. For sections B and C of the forms, always use Services You Can/Cannot Shop For, with the Borrower-Chosen Indicator as applicable. If you use the Did Shop/Did Not Shop For section for any given fee, it will not show up on the Loan Estimate.

My loan number is not appearing in the footer of the Loan Estimate or Closing Disclosure.

DocMagic understands that the CFPB's model forms disclose the loan number in the footer; however, such display is not a requirement of the regulation. As space at the bottom of the form is often needed for other information, including barcodes, this information was not included in the footer. Docmagic is working on creating a plan feature that would allow users to include the loan number, if desired.

My ETIA monthly totals look to be excluding the mortgage insurance (MI)?

This is correct. The regulation provisions for the Estimated Taxes, Insurance and Assessments specifically exclude mortgage insurance, i.e., items covered by 12 CFR 1026.4(b)(5), from this disclosure. The disclosure only provides information on property-related costs, in which mortgage insurance, as insurance against default on the loan, is not included.

I noticed the Escrow Account Disclosure on page 4 of the Closing Disclosure excludes mortgage insurance(MI). Is this correct?

The Escrow Account Disclosure generally refers to escrowed and non-escrowed property costs, in which mortgage insurance, as insurance against default on the loan, is not included. The regulation sections requiring this disclosure also refer to the amounts disclosed under the Estimated Taxes, Insurance and Assessments disclosure which specifically excludes mortgage insurance. However, since the Initial Escrow Payment disclosure refers to the amount collected at closing as shown on page 2 of the Closing Disclosure, MI that that is collected in the initial escrow payment would be included.

How does DocMagic handle the Down Payment calculation in the Calculating Cash to Close table?

Down Payment is the result of a specific calculation provided in the TRID rule: on a purchase transaction it is Sale Price minus principal amount of the loan. Because the rule requires subtracting the principal amount of the loan, and in the case of financed UFMIP, the principal amount of the loan is increased to cover the UFMIP amount, the calculation uses the Total Loan Amount rather than the Base Loan Amount. For a non-purchase transaction, this line is used for Funds from Borrower.

I am processing an FHA loan and I do not see my financed UFMIP amount in the Closing Cost Financed line of the Calcating Cash to Close table?

Closing Costs Financed is a specific calculation required by the TRID rule: Principal amount of the loan minus total amount of payments to third parties not disclosed as a closing cost. The result of the calculation, if positive, is disclosed on this line as a negative number but only up to the amount of the closing costs. If the result of the calculation is negative, zero is disclosed on this line.

My projected payments doesn't appear to be using my ceiling rate of 8.895% to calculate the maximum payment per month for my conventional loan.

The CD/LE follow the logic provided by the Note when determining the applicable maximum interest rate. In the case of FNMA note, the maximum interest rate would be rounded to the nearest 1/8th; therefore, the Projected Payments disclosure will use the maximum interest rate of 8.875% in your scenario.

I have a 5/1 ARM loan where the payment maxes at the 1st adjustment period, so shouldn't there just be two columns in the projected payments section? Why am I seeing four columns?

The rule states that you must disclose every time an interest rate may adjust, this is not dependent upon when the max rate is reached. For your example of a 5/1 ARM with a 30 year term, there are a total of 25 adjustments that can occur over the life of the loan, at the end of the fifth year and again at the end of every year thereafter. However, the rule allows only a maximum of four events to be disclosed. Because there are 25 disclosable events under the rule, the Projected Payments disclosure will show the maximum of four events.
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