The rule doesn't provide specific information on how to handle CTP loans, where the construction period ends on a day other than the 1st of the month.

Use of a different font does not strictly comply with the TRID Rule.  DocMagic has ensured its form templates for the Loan Estimate and Closing Disclosure comply with the Rule’s requirements for fonts. 

DocMagic consolidates to an addendum any information which does not fit on the pages provided for in the Closing Disclosure and which is allowed to be disclosed on an addendum under the TRID Rule.   The addendum follows substantially the same format as the rest of the Closing Disclosure as required by the Rule. 

If a fee name does not fit on a line, the best thing to do is to use commonly-used abbreviations to try and shorten it. The rule is silent on this issue, but the rule does not allow the moving of lines or sections of the form. Trying to shorten the description is the only permissible solution. There is a general "clear and conspicuous" standard that applies to the disclosure under 1026.17(a), including the naming conventions prescribed by 1026.37(f)(5). Under this standard, the description should be clear to the consumer and, essentially, understandable.

A maximum of 23 characters is allowed to cover all scenarios. Explanation: 1)  On the LE/CD, the width of the columns depends on whether there is a seller or not.  We'll expand the column when no seller is present, allowing more characters.  2)  The fill font used on both forms is the required Myriad-Pro, which is a proportional font where each character is a different width unlike the fixed width courier fill font where each character width is the same.

DocMagic will utilize the closing date as the consummation date, as this is generally accurate or the most conservative date under state law.   However, consummation under TILA is defined as the date the borrower becomes contractually obligated on the transaction which is determined by state law.   Accordingly, DocMagic will provide the option for users to select a different date as the consummation date, where needed. 

Yes, you must take state law into account for purposes of populating the correct late payment information.   Simply adding “ __ % of the monthly principal and interest payment”  -   would conflict with some notes, particularly second-lien notes, that provide for both a percentage and a specified dollar amount. The required language on the form leaves a substantial amount of space for information to be inputted, including the grace period before a charge will be imposed, the amount of a late charge and the basis on which it would be applied.

In a purchase transaction, this amount will always be disclosed as $0. For a refinance transaction, funds for borrower will equal the principal amount of extended credit less the total amount of all existing debt being satisfied in the transaction as a negative number.  A positive result to the above calculation would be disclosed as “Downpayment and other funds from borrower” and funds for borrower would be disclosed as $0.  See 12 CFR 1026.37(h)(1)(v).

1. Yes. DocMagic will include the Closing Disclosure in the pre-closing package.  The Closing Disclosure may also be ordered as a one-off document.  DocMagic will enable users to utilize our eSign platform to document the consumer’s receipt of the Closing Disclosure three business days prior to consummation.   In addition to the eSign platform, customers may use DocMagic’s in-house fulfillment to deliver paper copies of the Closing Disclosure to consumers.

On the alternate Loan Estimate for transactions without a seller, payoffs will appear in the Calculating Cash to Close table on page two (2) of the LE.  Payoff amounts will appear in the Payoffs and Payments table on page three (3) of the Closing Disclosure.  12 CFR 1026.37(h)(2)(iii).