Closing Disclosure Page 2

Working with 2015 RESPA-TILA Regulations 

2015 RESPA-TILA Workflow 

The Closing Disclosure input forms (pages 1-5) enable you to review, edit, or enter information that is populated to the Closing Disclosure output form that is provided to the borrower at least three business days prior to consummation. Use the Closing Disclosure Page 2 to review loan costs paid by the borrower, seller, and others at and before closing. Information on this form is populated from the 2015 Itemization form and cannot be edited. The fees are grouped into Loan Costs and Other Costs. This form is used to populate page 2 of the Closing Disclosure output form.

Loan Costs

The Loan Costs sections displays an itemized list of fees from the 2015 Itemization associated with loan costs:

  • Section A - Origination charges.

  • Section B - Fees for services that the borrower did not shop for.

  • Section C - Fees for services that the borrower did shop for.

  • Section D - Total loan costs from sections A, B, and C.

Sections A, B, and C

In these sections, each fee displays on a separate row that provides a description of the fee and the following columns for recording the fee amount, based on how the fee is recorded on the Fee Details pop-up window on the 2015 Itemization:

  • To - The recipient of the fee.

  • Borrower-Paid At Closing - The portion of a borrower-paid fee that is recorded as PAC .

  • Borrower-Paid Before Closing - The portion of a borrower-paid fee that is recorded as POC.

  • Seller-Paid At Closing - The portion of a seller-paid fee that is recorded as PAC.

  • Seller-Paid Before Closing - The portion of a Seller fee that is recorded as POC.

  • Paid by Others - The sum of all fee amounts paid by Broker, Lender, or Other that are recorded as PAC or POC. The amount is preceded by (L) when it is paid entirely by the Lender.

Click the Show More Lines link at the bottom of each section to display additional fees at the bottom of the list.

The total borrower-paid fees (including both At Closing and Before Closing fees) are listed in the Totals field below the Borrower-Paid columns at the bottom of each section.

Section D - Total Loan Costs (Borrower-Paid)

Section D displays the total borrower-paid fees for sections A, B, and C, including:

  • The total borrower-paid fees for each of the preceding three sections (Section A, Section B, and Section C).

  • The combined Total Borrower Paid Fees for all three sections. This amount displays in the Total Borrower Paid field and in the header area for this section.

  • The Total Borrower Paid Fees divided into fees that are paid At Closing and Before Closing.

Other Costs

The Other Costs sections displays an itemized list of fees from the 2015 Itemization that are not associated with loan costs:

  • Section E - Taxes and other government fees. The Recording Fees entered on lines 1202, 1206, 1207, and 1208 in the 1200. Government Recording and Transfer Charges section of the 2015 Itemization are aggregated and populated to line E01.

  • Section F - Prepaid fees.

  • Section G - Initial escrow payments at closing.

  • Section H - Other fees or services not associated with the loan costs and not included in sections E, F, or G.

  • Section I - Total loan costs from sections E, F, G, and H.

Sections E, F, G, and H

In these sections (except for section E), each fee displays on a different row that provides a description of the fee and the following columns for recording the fee amount, based on how the fee is recorded on the Fee Details pop-up window on the 2015 Itemization:

  • Borrower-Paid At Closing - The portion of a borrower-paid fee that is recorded as PTC .

  • Borrower-Paid Before Closing - The portion of a borrower-paid fee that is recorded as POC.

  • Seller-Paid At Closing - The portion of a seller-paid fee that is recorded as PTC.

  • Seller-Paid Before Closing - The portion of a Seller fee that is recorded as POC.

  • Paid by Others - The sum of all fee amounts paid by Broker, Lender, or Other that are recorded as PTC or POC. The amount is preceded by (L) when it is paid entirely by the Lender.

 The Recording Fees entered on lines 1202, 1206, 1207, and 1208 in the 1200. Government Recording and Transfer Charges section of the 2015 Itemization are aggregated and populated to line 01 in Section E, but are not itemized like the fees in sections F, G, and H are.

Click the Show More Lines link at the bottom of each section to display additional fees at the bottom of the list.

The total borrower-paid fees (including both At Closing and Before Closing fees) are listed in the Totals field below the Borrower-Paid columns at the bottom of each section.

Additionally:

  • Sections E (except for line 01), F, and H include To fields to record the recipient of the fee.

  • Section F includes To fields, and fields for the number of months and the monthly amount on all lines except Prepaid Interest.

  • Section G includes fields added for the monthly amount and number of months on all lines except Aggregate Adjustment.

Section I - TOTAL OTHER COSTS (Borrower-Paid)

Section I displays the total borrower-paid fees for charges that are not associated with loan costs, including:

  • The total borrower-paid fees for each of the preceding four sections (Section E, Section F, Section G, and Section H).

  • The combined total borrower-paid fees for all four sections. This amount displays in the Total Borrower Paid field and in the header area for this section.

  • The Total Borrower Paid Fees divided into fees that are paid At Closing and Before Closing.

Section J - TOTAL CLOSING COSTS (Borrower-Paid)

Section J displays the total closing costs (combined loan costs and other costs) broken down by borrower-paid fees, seller-paid fees, and fees that are paid by others.

  • The Closing Costs Subtotals (D+I) row displays the combined total of fees from the Total Loan Costs (section D) and Total Other Costs (section I) above. Borrower-Paid and Seller-Paid fees are broken down into At Closing and Before Closing amounts. Fees paid by someone other than the borrower or seller are listed in the Paid by Others column.

  • The Lender Credits field displays borrower paid fees that are recorded as lender credits. This amount is calculated based on the following three types of fees and payments recorded in Encompass:

  • Fees applied to the origination charge.

  • Fees with the Lender Credit option selected from line l entries in the Details of Transaction on the 2015 Itemization.

  • Amounts applied to cure a tolerance.

  • The Total Borrower Paid field displays the combined borrower-paid Closing Costs Subtotals (D+I) minus the Lender Credits. This amount also displays in the header area for this section.