SUBJECT: Updates to Access Investor Cash Flow Transactions
DATE: November 20, 2023
REMN is pleased to announce an improvement to our Non-QM Access Investor Cash Flow loan product, effective immediately. An ICF transaction will now be treated as a business purpose loan, and such, TRID requirements will no longer apply. Positives for this enhancement are enabling loans to close faster as well as a reduction in the amount of Loan Estimates and Closing Disclosures that need to be sent to the borrower.
Waived TRID Timing Requirements
The following TRID timing requirements will no longer apply:
- The 7-day waiting period from the time of the initial Loan Estimate to closing
- The 4-day waiting period from the time of the last Loan Estimate to closing
- The 3-day day waiting period from the time of the initial Closing Disclosure to closing
- The 1-day waiting period from the time of the last disclosed Loan Estimate to the Initial Closing Disclosure
- The 3-day day waiting period from the time of a COC Closing Disclosure when:
- The APR increased >.125%, or
- A prepayment penalty was added or removed, or
- The product type changes from a fixed rate to an ARM or from an ARM to a fixed
Re-Disclosure Changes
Below are pertinent details regarding REMN’s handling of disclosures:
- REMN will no longer need to disclose all change of circumstances on the Loan Estimate or Closing Disclosure within 3 business days
- The Initial Loan Estimate will continue to be disclosed at the time of loan set-up
- If the loan is locked after initial disclosures have been issued, a COC locked Loan Estimate will be disclosed to adhere to applicable state requirements
- Any additional changes (loan amount, pricing, term, etc.) will be captured and included on the initial Closing Disclosure (COC Loan Estimates will not be sent to the Borrower)
- The initial Closing Disclosure will continue to be sent to allow the Borrower and the Broker the opportunity to review loan terms and cash-to-close or cash-out
- Any COC changes that occur after the initial Closing Disclosure will not be disclosed until a final Closing Disclosure is sent with the loan package
- The initial Closing Disclosure can be sent the same the same day as a Loan Estimate (providing the loan is locked and a locked Loan Estimate has been sent)
Other federal and state regulations still apply, including appraisal delivery requirements being met before the loan may close.
This enhancement is effective for both new submissions and pipeline loans as of Monday, November 20, 2023, and applies to Access ICF loan only.
**Please contact your Account Executive with any questions**
