Análisis de Impacto de acuerdo a proyecciones de Año 1 y 2

• Origination Charges

• Dollar amounts rounded to nearest dollar; % to 2 or 3 decimals. • Indirect compensation of loan originator by creditor NOT shown

• Origination: includes app fee, orig fee, underwriting fee, processing fee, rate-lock fee, verification fee, mortgage broker fee, loan level pricing adjustment passed on to consumer (escrow waiver)

• Must include “__% of Loan Amount (Points)” and leave blank if 0;. • Cannot exceed 13 itemized charges.

• Points must be listed first, all others listed in alphabetical order • Clear and conspicuous standard applies

CLOSING COST DETAILS – LOAN COSTS: Services You Cannot Shop For; Services You Can Shop For (see page 34)

• CANNOT SHOP: Fees creditor requires for services by specified third parties

• CANNOT SHOP: Examples: appraisal, credit report, flood

determination, gov funding, homeowner’s association certification, lender’s attorney fee, subordination fee, title-closing protection, title- lender’s policy, up front MI

• Lender title policy cost disclosed without adjustment for simultaneous owner’s policy

• CANNOT SHOP: Cannot exceed 13 itemized items; alphabetical order

H-24(C) Mortgage Loan Transaction Loan Estimate - Interest Only Adjustable Rate Loan- pg 2

CLOSING COST DETAILS – OTHER COSTS: Taxes and Other Government Fees (see page 37)

• In general, for all “Other Costs,” disclose all charges required by agreement of sale to the extent creditor has knowledge

• Recording fees – any other government fees not transfer taxes are aggregated with recording fees.

• Transfer taxes – only portion imposed on consumer; portion imposed on seller not for Loan Estimate

• any fees based on loan amount or sale price no matter the name

• use apportionment provided by law or common practice if without agreement of sale

CLOSING COST DETAILS – OTHER COSTS: Prepaids (see page 37)

• Prepaids – Use precise language of model form; if no charge for a category, leave blank.

• Flood insurance premiums another example

• Prepaid interest: rate disclosed same as “interest rate” page 1 • Cannot delete subcategories; if not charged leave blank

• Maximum 3 additional subcategories can be added with time period and total

CLOSING COST DETAILS – OTHER COSTS: Initial Escrow Payment at Closing (see page 37)

• Use precise language of model form; if no charge for a

category, leave blank. Need monthly amount and number of months collected.

• “Aggregate account adjustment” not included in Loan Estimate • If different time frames for 2 property taxes, i.e. general and

school, can add another category.

CLOSING COST DETAILS – OTHER COSTS: “Other” (see page 37)

• Amounts consumer likely to pay not required by creditor • Example: “Title – Owner’s Title Policy (optional)”

• More examples: credit life, appliance warranties, real estate broker commissions, inspection fee not required by creditor. • Indicate “(optional)” for separate insurance or warranty

products.

CLOSING COST DETAILS – TOTAL CLOSING COSTS Lender Credits (see page 54)

• List as a negative number or leave blank (last line)

• Defined: Sum of payments from creditor to consumer for both non-specific overall credit and for specific fees

• “no cost loans” – cost of all fees shown as a “lender credit”

• If creditor represents that all or part of fees will not be paid, the “lender credit” must be sufficient to cover that sum

• “Good Faith”: if Closing Disclosure Lender Credit is less than that disclosed in the Loan Estimate, that is increased charge:

CLOSING COST DETAILS – CALCULATING CASH TO CLOSE (see page 37)

• Total Closing Costs minus closing costs paid out of loan proceeds

• Downpayment: purchase price minus principal; other: subtract principal from debt satisfied (if negative or $, disclose “0”)

• Deposit: negative number

• “Funds for Borrower” – only for loans not for purchase; for purchase “0”

• Formula: Satisfied debt minus principal loan amount:

• if answer is positive, disclose “$0” in “Funds from Borrower”

• if answer is negative, disclose that number in “Funds For Borrower”

• Seller Credits – disclose as negative number

• “Adjustments and Other Credits” – disclosed as a negative no.

• Gifts from family members;

• Home builder or developer providing a credit • Proceeds of subordinate funding

• “good faith” standard – inquire to borrower, review sales contract • amounts to be paid at closing by consumer under agreement of sale

• “Estimated Cash to Close” – all lines show “negative” number except first and Down Payment

CLOSING COST DETAILS – ALTERNATIVE CALCULATING CASH TO CLOSE – Refinance/Home Equity Option (see page 54)

• Optional, simpler format. If use, also use optional format at bottom of page 1 “Estimated Cash to Close”. (see page 52)

• Loan Amount, minus Total Closing Costs minus Estimated “Total Payoffs and Payments”

• “Estimated Total Payoffs and Payments” – amount to be paid to 3rd

parties not otherwise disclosed; i.e. payoffs of existing liens, judgments, outstanding debts required to be paid.

• Use check box to disclose if Estimated Cash to Close due from or to be paid to borrower

CLOSING COST DETAILS – Adjustable Payment (AP)Table (see page 34)

• Only appears if payment can change not based on rate, such as an interest-only feature; seasonal payment, optional

payment (biweekly) or step payment.

• Principal and Interest Payments: First change date and amount/range; subsequent change dates; and maximum payment amount and date.

CLOSING COST DETAILS – Adjustable Interest Rate (AIR) Table (see page 37)

• Use only when rate may increase either based on an index or scheduled changes.

• Index and margin, initial interest rate, min/max, first change date and subsequent, limits on rate changes

• Can abbreviate index: “LIBOR”

H-24(C) Mortgage Loan Transaction Loan Estimate - Interest Only Adjustable Rate Loan- pg 3

ADDITIONAL INFORMATION; “Other Considerations” (see pages 47, 48)

• Lender/Broker contact info and NMLS numbers

• “Comparisons” – 5-year total, APR and Total Interest Percentage (TIP) • “Appraisal” – takes the place of Reg B appraisal disclosure

• Reg B right to prompt copy only covers 1st _{lien loans}

• “Homeowner’s Insurance” – optional disclosure, but satisfies requirement for excluding premiums from finance charge

• “Late Payment”

• does not include simple interest accrual, but does include default rate • Include both dollar/percentage and number of days (grace period)

• “Construction Loan Redisclosure Notice – new construction, expectation loan will close after 60 days: “You may receive a revised Loan Estimate at any time prior to 60 days before consummation.”

• “Liability after Foreclosure” (see page 56)

• Only for refinance transactions; not permitted for other transactions!! • Warning that state law may remove protection against deficiency