Disclosure Tracking (2015 Version)

A Disclosure History entry is automatically added when:

• A document that is included in the Disclosure Tracking settings is requested from the borrower using the eFolder.
• A document that is included in the Disclosure Tracking settings is sent to the borrower as part of an initial disclosure (i.e., eDisclosure) package using the eFolder.
• A document that is included in the Disclosure Tracking settings is printed using the eFolder.

1. Click the New icon.
2. When prompted, select one or more disclosure types: Disclosure, Settlement Service Provider List, Settlement Service Provider List - No Fees, or Safe Harbor.

• When Disclosure is selected, select LE or CD to indicate whether the Loan Estimate or Closing Disclosure is being disclosed.

3. Click OK.

When you preview or print a document that is included in the Disclosure Tracking settings, a Disclosure Tracking prompt displays asking if you want to record a disclosure history record in the Disclosure Tracking tool. Click Yes to add the entry.

Note: Whether or not the Disclosure Tracking prompt displays when you print or preview a form is defined by your system administrator on the Disclosure Tracking Settings tool.

To Add an Entry Using the Prompt:

1. Open a loan, and then click the Forms tab.
2. Click the form in the list.
3. Click the Print icon.

• Click Preview to preview the document.
• Click Print, select your printing options on the Print window, and then click OK to print the document.

4. When the Disclosure Tracking prompt displays, click Yes.

Tip: Remember, the document must be included in the Document Tracking settings list or you will not be prompted to create a history entry when previewing or printing the document.

After an entry is added to the Disclosure History, it cannot be deleted. However, you can exclude an old or invalid entry so it is not included in the Compliance Timeline, LE Tracking, or CD Tracking sections. When a Loan Estimate or Closing Disclosure is excluded, the Disclosure Tracking summary dates are re-calculated. If the Loan Estimate or Closing Disclosure is the most recently disclosed version, the Last Disclosed fee in the Fee Details window on the 2015 Itemization and the disclosure date fields on the Loan Estimate or Closing Disclosure input form are updated to reflect the removal of the disclosure.

Note: A Loan Estimate cannot be excluded from the timeline when the Intent to Proceed checkbox is selected on the Disclosure Details pop-up window. The Intent to Proceed checkbox must be cleared before the first Loan Estimate can be excluded from the timeline. A Loan Estimate tracking entry that is excluded from the timeline can be modified, but the Intent to Proceed checkbox cannot be selected.

To Exclude an Entry:

1. Select the entry from the Disclosure History list.

2. Click Exclude From Timeline.

   • The entry is still visible in the Disclosure History, but it is no longer included in the Compliance Timeline, LE Tracking, or CD Tracking sections.

   • To add an excluded entry back to the timeline, select the entry and click Include in Timeline.

Note: When an excluded entry is included again, it retains the same values it had before being excluded. The disclosures are re-evaluated to determine the Disclosure Tracking dates. If a Loan Estimate or Closing Disclosure is included, and it is the most recently disclosed version of the Loan Estimate or Closing Disclosure, the Last Disclosed fee in the Fee Details window on the 2015 Itemization and the disclosure date fields on the Loan Estimate or Closing Disclosure input form are updated to reflect the removal of the disclosure.

The Details tab provides key information about the disclosure or disclosure package currently selected in the Disclosure History list.

• Use the Select Disclosure Recipient dropdown list to select the disclosure recipient, if applicable. The dropdown list only displays when there is a non-borrowing owner contact on the loan.

• Disclosure Details - This section included information related to the disclosure being sent and received.

• For a Loan Estimate entry, click the checkbox at the top of this section to indicate that the Loan Estimate was disclosed by the broker.

• The left panel displays a Disclosure Type dropdown field if the disclosure includes a Loan Estimate or Closing Disclosure. You can change the default selection if needed, but changing the default is recommended only for a final Closing Disclosure.

• The left panel provides the disclosure or disclosure package's Sent Date, by whom it was sent, and the method by which it was sent.

• Click the blue Lock icons to manually enter a Sent Date date or to change the name of the individual who sent the disclosure.

• To change the Sent Method used to send the disclosure or disclosure package, select an option from the dropdown list. If the Other option is selected, enter a description in the text field.

• The left panel displays an Intent to Proceed checkbox if the disclosure includes a Loan Estimate. The checkbox is selected by default if the borrower has received the Loan Estimate. If the checkbox is selected, it must be cleared before it can be selected for another Loan Estimate disclosure entry.

• If the Intent to Proceed checkbox is selected, you can edit additional fields associate with the checkbox, including:

• Type or select a new Intent to Proceed date as needed.

• Click the Lock icon to edit the name of the Encompass user who selected the Intent to Proceed checkbox.

• Select the method by which you received the intent to proceed. If you select Other, type a description in the text field.

• Additional comments can be entered manually in the Comments field.

  Note: If the Intent to Proceed checkbox is selected, the Intent to Proceed information on the Details tab is the same as the Intent to Proceed information on the Loan Estimate Page 1. Changes made to the information in either the form or the tool are populated to both locations.

• The left panel displays a Use for UCD Export checkbox if the disclosure includes a Closing Disclosure (CD). This checkbox enables users who send UCD (Uniform Closing Dataset) files to Fannie Mae or Freddie Mac to indicate the CD (Closing Disclosure) to send. Only one disclosure can be indicated as the disclosure to send for UCD.

• The Use for UCD Export checkbox is provided in the Disclosure Details window for each CD record in the tool. Select this checkbox in the CD record you want to send to Fannie Mae or Freddie Mac.

• The right panel displays information related to how and when the borrower and co-borrower received the disclosure or disclosure package.

• Use the dropdown menu to change the borrower or co-borrower Received Method or Actual Received Date.

• Click the Lock icons to change the borrower or co-borrower Presumed Received Date fields.

Note: The earliest of the borrower presumed receipt or actual receipt is reflected as the received date in the LE Tracking section. The latest of both the borrower and co-borrower presumed and actual receipt dates is reflected in the CD Tracking section.

• Loan Snapshot - This section provides the key loan fields that were disclosed to the borrower. A snapshot button displays for each of the following forms that were sent. Click a snapshot button to view a read-only copy of the disclosure information.

• LE Snapshot (Loan Estimate) - LE Snapshots include tabs that show the content on each page of the Loan Estimate form, plus a Fee Changes tab that displays a Fee Changes table that lists the fee description, new fee amount, a description of the changed circumstance, comments, reason for the changed circumstance, and the Changes Received Date.

• CD Snapshot (Closing Disclosure) - CD Snapshots include tabs that show the content on each page of the Closing Disclosure form.

• Safe Harbor Snapshot (Anti-Steering Safe Harbor Disclosure)

• SSPL Snapshot (Settlement Service Provider List)

• Itemization Snapshot ( 2015 Itemization) - All sections are collapsed by default, but can be expanded. A read-only version of the Fee Details pop-up window can be opened for each fee.

• Documents Sent - This section lists the disclosure documents that were sent to the borrower. For documents that were sent electronically in an eDisclosure package, click the View Document button to view a read-only copy of the documents.

Note: This tab displays only when you have selected a Disclosure History record for a disclosure package that includes a Loan Estimate or Closing Disclosure.

The Reasons tab displays information that describes the purpose of a revised disclosure. The information is populated from the Loan Estimate (LE) Page 1 or the Closing Disclosure (CD) Page 1. You can edit information on the tab, but the edits are not copied back to the Loan Estimate or Closing Disclosure form.

If a loan is being disclosed at a fee level, the Fee Level Disclosures checkbox on the Reasons tab will be selected and a Change of Circumstance reason for each fee variance should be documented. Only one reason can be selected for each fee variance. If no reason is selected (reason is blank), it will be considered an invalid reason when calculating the baseline on the Fee Variance Worksheet.

• Use the Reason section to select one or more checkboxes that describes the reason for the redisclosure. If you select Other, enter a description in the text field.
• In the Changed Circumstance section, click the Select icon (magnifying glass) to populate the Changed Circumstance field from a predefined list, and then type comments in the Comments field as needed.
• If a loan is being disclosed at a fee level, all individual fee level changed circumstances are populated to the Changed Circumstances field automatically as indicated on the LE Page 1 or CD Page 1 (one changed circumstance per line).

• All individual fee level Comments are populated to the Comments field
• The date the fee changed and the date when the changes were received can be entered here. The revised LE or CD due date field is automatically populated.
• If disclosing at a fee level, the Fee Changes table is provided and the following details for each fee change are provided. (This is a read only table, and cannot be edited.):
  • Fee Description
  • New Amount ($)
  • Description of change
  • Comments (i.e., the fee level comments listed in the Comments field)
  • Reason
  • Changes Received Date

Note: This tab displays only when you have selected an eDisclosure package entry in the Disclosure History list.

The eDisclosure Tracking tab provides the dates when the borrower and co-borrower take action on the selected eDisclosure package and details about the latest eDisclosure Fulfillment Service package that was printed and sent to the borrower (if applicable).

• Click View Details to open the original email message (including the From: and To: email addresses) that was sent to the borrower when sending the eDisclosure package.
• Click View Form to view the eDisclosure Agreements (PDF) for the borrowers.
• The read-only fields in the Status section are auto-populated with the date on which the borrower and co-borrower (if applicable) access, accept, reject, or electronically sign the eDisclosure package. In addition, the ePackage ID is provided. This ID is captured to easily identify valid eDisclosure package orders. (The capturing of this ID was introduced in the Encompass 18.3 Major Release. View the release notes.)
• The read-only fields in the Fulfillment section are auto-populated with the date on which the latest eDisclosure Fulfillment Service package was created and sent to the borrower, by whom the package was ordered, the presumed date the borrower will receive the package, and the actual date the borrower received the package.
• If your administrator has given you permission in the Persona settings, you can click Print Documents and Manually Fulfill to print and manually send the documents. After you print the documents, the Manually Fulfill window displays. Select a fulfillment method, enter comments as needed, and then click Submit.