Mortgage Disclosure Improvement Act (MDIA)
Mortgage Disclosure Improvement Act (MDIA) Effective July 30th.
What everyone needs to know!
(Every Lender in the U.S. is affected)
On every loan, we have always had to provide a Federal Truth in Lending Disclosure (the one with the APR on it). In the past, we had to disclose this to the consumer within 3 days. The rule has now been changed to 7 business days (Saturday is considered a business day). This is called the initial disclosure which I do at application. If the customer does not lock the rate and waits until a later point in time, we are then required to re-disclose if there is a change from the initial disclosure at least 3 business days prior to closing. A loan can not close unless the above timeframes are satisfied (no exceptions). Keep in mind this is just the beginning of changes that our happening in our industry.
Appraisal Reminders
All lenders are required to rotate appraisers. Most lenders are using management companies and they can pull from within a 45 mile radius. That means a home on the beach could be appraised by a Plant City appraiser and vice versa. If you use just “anybody”, you may find that your appraisals are coming in low. For example, I had a purchase close last week that Bank of America brought in 100K less than my appraisal and we closed the loan when they could not.
