norris conference center - austin february 19, 2015 · 2017-04-18 · 2. closing disclosure (cd)...

Norris Conference Center - Austin

February 19, 2015

9:30 a.m. Registration 10 Key Components of the New Regulations ................................................ 11 Marvin Stone, Stewart Lender Services 10:30 What Goes Where on the New Form ........................................................ 27 Dawn Marie Lewallen, Stewart Title Guaranty Company Thomas F. Vetters II, Robertson Anschutz Vetters Noon Luncheon Presentation Tom Rhodes, President of Texas Mortgage Bankers Association; President & CEO, Sente Mortgage 1 p.m. Q&A with the Experts 1:30 Changing Roles, Responsibilities and Processes .................................... 53 A Panel Discussion featuring: Teresa Frost, CTIA, National Investors Title Insurance Company Denise Holmes, Independence Title Company Dawn Marie Lewallen, Stewart Title Guaranty Company Marvin Stone, Stewart Lender Services 2:30 New Timelines from Loan Approval to Closing ......................................... 63 Denise Holmes, Independence Title Company 3 Adjourn

Continuing Education:

Escrow Officers or General Attendance: Up to 4.5 hours of continuing education credit is available from the Texas Department of Insurance. Attorneys: This seminar has been approved for Minimum Continuing Legal Education (MCLE) credit by the State Bar of Texas Committee on MCLE for a total of 4.5 credit hours. Attendance forms for Escrow, Attorney and General credit will be handed out in class at the end of the day. Please place completed forms in the box at the back of the room. Real Estate Agents & Brokers: Since this seminar has been approved by the State Bar of Texas for MCLE credit, the Texas Real Estate Commission will award *MCE credit for real estate licenses. TREC Course completion certificate and credit request forms will be available at the TLTA registration desk at the end of the day. *At least 6 of the 15 classroom hours of Commission approved Mandatory Continuing Education must consist of a 3 hour legal update course and a 3 hour legal ethics course created for and approved by TREC to satisfy the 6 legal hours of MCE required by Occupations Code §1101.455. 1

RESPA/TILA Readiness Training Series

Thank you

to all of our

Experienced

Presenters

3

TERESA H. FROST Vice President, Texas Agency Manager

National Investors Title Insurance Company

Title Insurance Experience

Teresa is the Vice President and Texas Agency Manager for National Investors Title

Insurance Company. She began her title insurance career in 1977 in Refugio, Texas

working for a law firm and Refugio County Abstract & Title. Her main job was

making sure the “take-offs” were completed from the courthouse and entered in the

tract books. Since that time, she has had numerous positions in the title industry. She

has progressed through the ranks and counts herself blessed to have found her career in

the world of title insurance. Her love of education has contributed to her being able to

teach and train the agents of NITIC and others through her volunteer efforts for the

Texas Land Title Association.

Industry Activities

Certification – Certified Title Insurance Associate CTIA

Served and/or Chaired Committees:

TLTA Basic School Chairman 2011 – 2015

Education Committee

Membership

Conference

Certification Task Force

Women’s Council of Realtors

Women in Business

Texas Land Title Association Honors

Title Person of the Year 2014

Super Star Award 2008

Peggy Hayes Teaching Excellence Award – 2007

Professional Excellence Award – 2006

Training and Teaching Experience

TLTA Land Title School – 1999 to Present

TLTA Seminars and Webinars – 1999 to Present

Certified TREC MCE Instructor – 2006 to Present

Underwriter Courses and training for Texas Agents - 1995 to Present

5

Instructor Profile

Name: Denise Smith Holmes (f/k/a Denise S. Werst)

Company Name: Independence Title Company, Vice President - Policy and Compliance

National Investors Title Insurance Company - Texas Regulatory Compliance

Coordinator

Title Industry Background: Currently responsible for assuring federal and state regulatory compliance, as well

as managing the Policy Department for Independence Title Company. Other responsibilities include escrow

and policy training. Prior experience with a national title agency included software application and escrow

closing training at a national level. Previous experience with two different underwriters included performing

escrow accounting and underwriting audits in Texas and New Mexico, with significant emphasis placed on

conducting in-house training seminars for agents.

Denise began her title insurance career in the early 1980’s. She worked for a title agency licensed in three

south-central Texas counties. She learned the escrow accounting and closing functions as well as title search

and examination positions before becoming the General Manager, a position she held for approximately four

years before returning to school to obtain an accounting degree. In addition, Denise has title insurance

experience in New Mexico.

Honors:

2010-Present TTIGA Board – Underwriter Member

2005 TLTA Peggy Hayes Teaching Excellence Award, recipient

2002 TLTA Professional Excellence Award – Agency Support Personnel, recipient

Committee Appointments:

Texas Land Title Association

TLTA - TDI Basic Manual joint task force, Chair

TLTA Federal Issues Committee, current member

TLTA Education Advisory Committee, current member

TLTA Statistical Reporting task force, current member

TLTA Judiciary Committee, member 2010-2011

TLTA Certification Committee Inception to 2010, member

TLTA School and Advanced Title Issues Committee, 1995-2004, member

Chairperson, 2000-2001 and 2001-2002

Vice Chairperson, 1999-2000

TLTA Institute Committee, member 1999-2002

Young Title People of Texas Committee, member 1995-1996

Educational Background:

B.B.A., Accounting, University of Texas at San Antonio, 1991

B.S., Animal Science - Science Option, Texas A&M University, 1979

Previous Teaching Experience:

• 2014 Owning and Managing a Title Agency Seminar, speaker

• 2014 Texas Land Title School Policy Workshop, speaker

• 2010 HUD-1 Workshops, speaker

• TLTA Right Rules, Correct Calculations Workshop, 2004-2005, speaker

• Policy Workshop Seminar, 2002-2003, speaker

• TLTA Regional Seminar Series, 1997-1998, 2000-2005, speaker

• Texas Land Title School, March 1997 – 2003, speaker

• New Mexico Land Title Association, Mid-Winter Convention, 1995, 1997, 1998, and 2000, speaker

• New Mexico Land Title School – 1998 and 2000, speaker

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DAWN M. LEWALLEN

Dawn Lewallen is Compliance Counsel for Stewart Legal Services, Stewart Title

Guaranty Company at its headquarters in Houston, Texas. She serves on Stewart’s

CFPB Task Force as the legal consultant for the training and implementation of the

Integrated Mortgage Disclosure Rule. She also advises on underwriting and other

compliance related matters throughout the Stewart affiliated companies. Dawn

received her Bachelor's Degree from Goucher College in Towson, Maryland and

her Juris Doctorate, from Saint Louis University in St. Louis, Missouri. Following

several years in private practice, she joined Stewart Title Guaranty’s in 2000.

Most recently she served as Georgia State Counsel and Senior Underwriter for

Stewart based in Roswell, Georgia.

Dawn has written and lectured on real estate and title insurance subjects for the

land title associations, the State Bar of Georgia, financial institutions, builder and

realtor associations and title companies throughout the country.

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TOM RHODES BIO

Tom Rhodes is the current President of the

Texas Mortgage Bankers Association. With

over 320 member companies, the TMBA is a

non-profit focused on preserving,

enhancing and advancing the interests of

mortgage banking in the state of Texas. As

President, Tom is responsible for

supervising the business and affairs of the

Association and running member and board

of director meetings.

Tom’s day job is CEO of Sente Mortgage, a

Texas-based mortgage bank he co-founded

in 2007.

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Marvin Stone CFPB Program Manager Senior Vice President, Business Integration Stewart

arvin currently holds the position of senior vice president of business integration and currently

serves as the CFPB program manager for Stewart. Since joining Stewart in 2007, Marvin has

overseen a wide variety of technology and process improvement initiatives, all designed to better

support Stewart’s network of Trusted Providers. Prior to joining Stewart, he served as chief

information officer for a large, West Coast title agency, as well as holding customer‐serving technology

positions with other national underwriters. Previous to entering the title industry, Marvin was in a

management role for a national mortgage lender.

M

9

Thomas F. Vetters II Board Certified, Residential Real Estate

Texas Board of Legal Specialization

Thomas Vetters graduated from Texas A&M University and South Texas College of

Law. While in law school he clerked for the Honorable Judge Dwight Jefferson in the

215th Civil District Court in Harris County, Texas. After finishing his judicial clerkship

Thomas joined the law firm of Robertson & Anschutz, PC in Houston. Thomas has been

a past chair of Regulatory Compliance committee for the Texas Mortgage Bankers

Association (“TMBA”) where he served as Editor for the TMBA Deskbook. He has

served as part of the executive team for TMBA as well as two terms as a board member.

Thomas co-authored the Texas Bankers Association (“TBA”) Home Equity Manual and

is currently working with co-author John Fleming to update the manual for a Spring 2015

release. He is Board Certified in Residential Real Estate Law by the Texas Board of

Legal Specialization and his primary practice areas include real estate law and regulatory

compliance on both state and federal issues. He is a member of the College of the State

Bar of Texas, the State Bar of Texas Real Estate, Probate and Trust Section and the Texas

Land Title Association. He is a partner with the law firm of Robertson Anschutz Vetters

and offices in Austin, Texas.

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Key Components of The New Regulations

Presented by

Marvin Stone Stewart Lender Services

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2015 TLTA RESPA/TILA ©2013 Alliant National Title Insurance Company, Inc. All Rights Reserved Page 1 of 4

TILA / RESPA Integrated Disclosures (TRID)

A Refresher

I. Introduction

A. Effective Date

Most provisions apply to applications received by creditor or mortgage broker on and after August 1, 2015.

B. Coverage

1. Applies to most closed-end consumer mortgage loans

2. Does not apply to

• Home equity lines of credit (which are also not subject to RESPA)

• Reverse mortgages (which continue to be subject to RESPA)

• Mortgages secured by mobile homes or by dwellings not attached to property (if the mobile home is real property, the rule does apply).

• Creditor that makes five or fewer mortgage loans in one year

• Certain narrowly defined subordinate liens [see 1026.3(h) of the Final Rule]

• Loans that are not “consumer loans” – such as commercial or business purpose loans

C. Terminology

1. Lender = “creditor”

2. Borrower = “consumer”

3. Tolerance = “variation”

4. Closing/Settlement = “consummation” – most lenders consider this to be the date on which the borrower signs the loan documents

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TRID – A Refresher


D. The rule includes two primary new forms and instructions for how these forms are to be prepared and delivered to consumers. (12 CFR § 1026.37)

1. Loan Estimate (LE) – Model Form H-24 with variations (12 CFR § 1026.37) • Provided to consumer (by lender or broker) within 3 business days after

submission of loan application • Replaces early TIL statement and GFE • Provides summary of key loan terms and estimates of loan and closing costs • Includes “Cash to close” • Idea is to promote comparison shopping

2. Closing disclosure (CD) – Model Form H-25 with variations • Provided to consumer by lender or settlement agent • Received by consumer 3 business days before consummation • Replaces final TIL statement and HUD-1 settlement statement • Provides detailed accounting of transaction.

o Loan Terms o Final Costs o Comparison of LE with final terms and costs

II. Top Takeaways in Final Rule

A. Definition of “Business Day” – Not one, but two definitions

1. When providing the Loan Estimate to consumer within three business days of application

• A “business day” is defined as a day on which the creditor’s offices are open to the public to carry on substantially all functions

2. Waiting period between Loan Estimate and consumer receipt of Closing Disclosure – and between Closing Disclosure and closing

• A “business day” is defined as all calendar days except Sunday and certain specified federal holidays

B. Timing of Disclosures

1. Loan Estimate (LE) – “Application” is the trigger Creditor must deliver or place in the mail no later than 3 business days after

Application Creditor must deliver or place in the mail not later than the 7th business

day before closing. If not provided in person, consumer is considered to have received 3

business days after it is delivered or placed in the mail. Waiting period can be waived for bona fide financial emergencies based on

written statement by consumer – no printed forms allowed Must re-disclose within three business days of learning of a change

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2. Closing Disclosure (CD) Consumer must receive 3 business days before consummation – unless

• Bona fide personal financial emergency – written statement by consumer – no printed forms

If not provided in person, the consumer is considered to have received 3 business days after it is delivered or placed in the mail.

Seller must receive no later than day of consummation

3. Subsequent Changes – CD becomes inaccurate before closing: Some changes before closing require re-disclosure and a new 3-business-

day waiting period • The Annual Percentage rate changes above APR tolerance • Change to loan product • Addition of prepayment penalty

Otherwise, corrected disclosure at or before consummation • Consumer must be able to inspect one business day prior to

consummation

4. Subsequent Changes – CD becomes inaccurate after closing: Changes post-closing that require revised Closing Disclosure

• Discovery of an inaccuracy related to settlement during the 30 days after closing resulting in a change to an amount paid by consumer and/or seller = redisclose within 30 days after learning event occurred

• Non-numeric clerical errors = redisclose within 60 days after consummation

Refunds related to the good faith analysis – variation (tolerance) violation occurs = refund and redisclose within 60 days after consummation

C. Who Provides Disclosure?

1. Loan Estimate to consumer – either Creditor or Loan Broker may prepare and provide • Creditor still liable/responsible • Name of Lender is always the Creditor, not the Broker. If the Broker does not

yet know the Creditor, name of Lender is left blank.

2. Closing Disclosure to consumer – either Creditor or Settlement Agent may prepare and provide • Creditor still liable/responsible – and, therefore, is most likely to prepare

3. Closing Disclosure to Seller – Settlement Agent must prepare and provide • The disclosure must reflect the actual terms of the seller’s transaction. • Disclosure must be provided to seller no later than the day of consummation. • Seller’s Disclosure may be on a separate form from the Borrower’s

Disclosure • If an amount changes, settlement agent must redisclose not later than 30

days after receiving information to establish the change occurred. • Must also provide copy of seller Closing Disclosure to creditor

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D. Written List of Providers (Model Forms H-27B and H-27C)

If the consumer is permitted to shop for a settlement service, the creditor must provide consumer with a Settlement Service Providers List (SSPL)

E. Itemization of Fees and Charges

The amount imposed upon the consumer (or seller) for any settlement service shall not exceed the amount actually received by the settlement service provider for that service – unless it is an Average Charge.

All fees and charges must be separately itemized. Fees and charges must be listed alphabetically.

• All title insurance charges (including settlement agent fee) must be preceded by “Title –“ followed by a description of the fee.

• Fee for owner’s title insurance must be followed by the word “optional” because it is not required by the Creditor, but is something the consumer may choose to purchase.

F. Variations – the new word for “Tolerances”

The creditor must give the consumer the “best information reasonably available;” however, variations between amounts on the Loan Estimate and on the Closing Disclosure are permitted, as follows:

1. No Variations (current Zero Tolerance Bucket) expanded to include:

• Affiliate charges

• Fees paid to unaffiliated SSP (Settlement Service Provider) for which consumer cannot shop

2. Limited Increases (current 10% Tolerance Bucket)

• Charge paid to unaffiliated SSP selected from creditor’s SSPL (Settlement Service Provider List)

3. Variations permitted (current No Tolerance Bucket)

• SSP selected by consumer and not on the SSPL

• Charges for services not required by the creditor

• Prepaid interest

• Property insurance premiums

• Escrow amounts, impound reserves

G. Changed Circumstances still exist

1. “Good faith” for purposes of fee variation rules can be determined based on a revised Loan Estimate if:

• The revised LE is provided within 3 business days of receiving information establishing that a reason for revision applies.

2. The revised Loan Estimate cannot be delivered on same day as delivery of the Closing Disclosure – and cannot be delivered after the CD has been delivered.

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RESPA/TILA Readiness Training Series:What Happens to the HUD-1 on August 1?

A Refresher

TEXAS LAND TITLE ASSOCIATION

INTRODUCTION

• Effective dates

– Most provisions apply to applications received by creditor/broker on and after August 1, 2015

17


COVERAGE

• New disclosures apply to most closed‐end consumer mortgage loans

• New disclosures do not apply to

– Home equity lines of credit (not subject to RESPA)

– Reverse mortgages (subject to RESPA)

– Personal property mobile home transactions

– Creditor making 5 or fewer loans in a year

– Certain special‐type subordinate liens

– Loans that are not “consumer loans”


Terminology

• Terminology

– Lender = “creditor”

– Borrower = “consumer”

– Tolerance = “variation”

– Closing/Settlement = “consummation” – but what does that mean?

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LOAN ESTIMATE (LE)

• Model Form H‐24 with variations

• Provided to consumer – by lender or broker

– Within 3 business days after application

• Replaces early TIL and GFE

• Contains:

– Summary of key loan terms

– Estimates of loan and closing costs

– Includes “cash to close”

• Idea is to promote comparison shopping


CLOSING DISCLOSURE (CD)

• Model Form H‐25 with variations

• Provided to consumer – by lender or settlement agent– Must be “received” 3 days or more before closing

• Replaces final TIL and HUD‐1

• Provides a detailed accounting of the transaction– Loan terms

– Final costs

– Comparison of LE with final terms and costs

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2 Definitions of “Business Day”

• Provision of LE to consumer within 3 business days

– Business day = Day on which the creditor’s offices are open to the public to carry on substantially all functions

• Waiting period between LE and consumer receipt of CD – and between CD and closing

– Business day = All calendar days except Sunday and certain Federal holidays.


Timing of Disclosures

• Loan Estimate (LE) – “Application” is trigger

– Must deliver or place in mail no later than 3 business days after application

– Must deliver or place in mail not later than the 7th business day before closing

– Consumer considered to have received 3 business days after delivered or placed in mail

– Waiting period between LE and closing can be waived for bona fide financial emergency

– Must re‐disclose within 3 business days of learning of a change (“changed circumstance”)

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Timing of Disclosures

• Closing Disclosure (CD)

– Consumer must receive 3 business days before consummation (closing)

• Waiting period may be waived for bona fide financial emergency

– Consumer considered to have received 3 business days after delivered or placed in mail

– Seller must receive no later than closing


Subsequent Changes

• CD becomes inaccurate beforeclosing

– Some changes require re‐disclosure and a new 3‐day waiting period

• APR changes above tolerance levels

• Loan product changes

• Addition of prepayment penalty

– Otherwise• Provide corrected disclosure at or before closing

• Consumer must be able to inspect one business day prior to closing

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Subsequent Changes

• Changes after closing require revised CD– Event related to settlement

• Re‐disclose within 30 days after learning the event occurred

– Non‐numeric clerical errors• Re‐disclose within 60 days after closing

– Refunds related to the good faith analysis

• Variation (tolerance) violation

• Refund and re‐disclose within 60 days after closing


Who Provides Disclosures?

• Loan Estimate to consumer

– Creditor or Loan Broker

– Creditor fully liable/responsible

• Closing Disclosure to consumer

– Creditor or Settlement Agent


• Closing Disclosure to seller

– Settlement Agent

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Written List of Providers

• If consumer is permitted to shop – creditor must provide consumer with Settlement Service Providers List (SSPL)

– At least one provider for each service

– SSPL must be on a separate sheet of paper

– Same timing as LE


Itemizing Fees and Charges

• Amount imposed on consumer – or on seller – for any settlement service shall not exceed the amount actually received by the settlement service provider for that service – unless it is an Average Charge (not permitted in Texas).

– Fees must be separately itemized

– Fees and charges must be listed alphabetically

– Title insurance charges (including closing fee) must be preceded by “Title –”

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Variations = Tolerances

• Category where no variation is allowed (current Zero Tolerance bucket)

– Creditor’s own charges

– Charges by affiliates of creditor

– Fees paid to unaffiliated SSP for which consumer cannot shop

• Category where limited increases are allowed (current 10% bucket)

– Charge paid to unaffiliated SSP selected from the SSPL provided by creditor


Variations Permitted

• SSP selected by consumer and not on SSPL

• Charges for services not required by creditor

• Prepaid interest

• Property insurance premiums

• Escrow amounts, impound reserves

• However – creditor must give consumer the “best information reasonably available”

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Changed Circumstances

• “Good faith” for purposes of fee variation can be based on a revised LE under specified circumstances.

• Creditor must provide revised LE within 3 business days of learning of the change.

• Creditor may not provide a revised LE on the same day as delivery of the Closing Disclosure

25


What Goes Where on the New Form

Presented by

Dawn Marie Lewallen Stewart Title Guaranty Company

Thomas F. Vetters, II Robertson Anschutz Vetters

27

TLTA 2015 RESPA/TILA ©2013 Alliant National Title Insurance Company, Inc. All Rights Reserved Page 1 of 14

TILA / RESPA Integrated Disclosures (TRID) Closing Disclosure: A Line by Line Look

For this session, we are using the H25-B Sample Form published by the CFPB for a Fixed Rate purchase money loan. We will start with Page 1.

This part of the form is divided into three informational sections. Notice that only the names of the Settlement Agent and Lender are shown. Contact information for these parties, as well as for the Loan Broker and Real Estate Agents appears on the final page of the form.

Date Issued The date on which the Closing Disclosure is delivered to the borrower (by hand, mail, fax or email). Note: Since on the sample the “Date Issued” and the “Closing Date” are the same, this CD

must be an example of a revised CD given at the closing table or an example of a transaction where the 3-day waiting period was waived by the borrower because of financial hardship. (Note: This waiver of the 3-day waiting period is unlikely to be permitted by the lender.)

It is worth noting that Date Issued will change as revised CDs are issued, just like the Date Issued on the Loan Estimate changes as revised LEs are issued.

Closing Date The date on which the borrower signs the loan documents.

Disbursement Date The date on which the lender funds the loan.

File # The settlement agents file number (GF #)

Property Street address of the property. Although the regulations do not specify, a ZIP code should be provided, as shown in the sample. If the property does not have a 911 address, at a minimum the ZIP code must be shown.

Sale Price This is the sales price for the real property.

Borrower The names and mailing address for all borrowers. Note: The name and address of each consumer and seller in the transaction must be

disclosed. If there is not enough space to show the name and address of all consumers and sellers in the transaction, an additional page may be used and appended to the end of the Closing Disclosure.

Seller The names and mailing address for all sellers.

Lender Name of the lender. Note: The Lender is always the Creditor, not the Broker.

Loan Term The term of the loan

Purpose The purpose of the loan. If it is a sale transaction, it would be “purchase” as shown in the sample. For other types of loans it might be “refinance” or “construction,” etc.

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TRID – Line by Line Look at the Closing Disclosure


Product This refers to the loan product, such as “fixed rate” as in the sample, or “adjustable rate,” etc.

Note: If the Loan Product changes after the initial CD is issued, .a revised CD must be received by the borrower at least 3 days before closing – in other words, there is a new 3-day wait.

Loan Type Check a box to indicate whether the loan is a “conventional” loan (whether insured or not), an FHA loan, a VA loan, or some other type of loan.

Loan ID # The loan number assigned by the Creditor (Lender), not the Broker.

Note: The regulations permit a Creditor to add a hyphen and additional number to the Loan ID in the LE to indicate the number of revised LEs issued in sequence. On the CD, the Creditor must use the same Loan ID (which preceded the hyphen) to enable matching the LE (whether one or more) with the CD. We are waiting for guidance as to whether a hyphen and revision number may be added to the Loan ID on a CD.

MIC # The Mortgage Insurance Case number, if applicable.

Page 1 continued: In this section of the form, titled LOAN TERMS, the lender gives the borrower information about the terms of the loan, and when required, an explanation. It is self-explanatory.

In the next section, labeled PROJECTED PAYMENTS, the lender provides the borrower an estimate of the monthly payments with an emphasis on showing payment changes. In this sample, the borrower’s payments will go down because mortgage insurance is only required for the first 7 years of the loan. Depending on the features of the loan, this section can have up to four columns.

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The final section on the first page, titled COSTS AT CLOSING, may be difficult for the borrower to understand, since he has not yet seen the breakdown of the actual costs. He will see the Closing Costs amount at the bottom of Page 2 and the Cash to Close amount at the bottom of Page 3.

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Page 2 is divided into two sections – Loan Costs and Other Costs. If the fees/charges on this page cause the page to exceed the maximum length for printing on letter-size paper, the two sections are to be presented on separate pages numbered Page 2a (for Loan Costs) and Page 2b (for Other Costs).

For each charge, the “name” of fee/charge appears first, followed by the party to whom it is paid (except in Section A where only charges paid to the Lender are listed).

The names used for the fees/charges on the Closing Disclosure must match the names used for the same fee/charge on the Loan Estimate received by the borrower.

All fees/charges for title related services, including the Settlement Agent fee, must begin with the word “Title” followed by a space, a hyphen, and another space, as shown in the sample.

In each part, the fees/charges must appear in alphabetical order.

For each product/service – the amount fee/charge is placed in one or more of 5 separate columns depending on who is to pay the charge (Borrower, Seller or someone else) and whether it will be paid At Closing or Before Closing.

From the CFPB Guide to Completing the Forms: To the extent that an individual item is paid by different parties to the transaction and both at and before closing, the amounts associated with an item can be entered in multiple columns.

If a Seller has agreed to pay a specific fee/charge, the amount should appear in the appropriate Seller-Paid At Closing or Before Closing column, even if it was an fee/charge disclosed to the borrower on the Loan Estimate.

From the CFPB Guide to Completing the Forms: Seller Credit is an amount the seller is giving as a general credit not tied to a specific charge on page 2 or is making as an allowance to the consumer for items to purchase separately. (§ 1026.38(k)(2)(vii)) The amount of Seller Credit would include any credits to the consumer as the result of a walk-through of the property prior to the closing. (Comment 38(k)(2)(iv)-2)

However, if the amount of a credit is attributable to a charge listed on page 2, then the amount should be listed with the applicable item on page 2 and designated as Seller-Paid At Closing or Seller-Paid Before Closing, as appropriate. (Comment 38(j)(2)(v)-1)

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Page 2:

Charges/fees appearing in the Loan Costs section are for products or services that were required by the lender as a condition of the loan.

• A. Origination Charges = The lender’s own fees; or • B. Services Borrower Did Not Shop For =

o Items for which the lender did not allow the borrower to shop, and o Items for which the borrower was allowed to shop, but selected a vendor/provider from

the Settlement Service Providers List (SSPL) delivered by the lender; or • C. Services Borrower Did Shop For = items for which the lender allowed the borrower to

shop but selected a vendor/provider that was not on the SSPL.

Part A – Origination Charges Fees/charges the borrower will pay to the lender and loan originator for originating and extending the credit.

Part B – Services Borrower Did Not Shop For

Fees/charges for products/services • For which the lender did not permit the borrower to shop or • For which the borrower selected a provider from the SSPL.

Part C – Services Borrower Did Shop for

Fees/charges for products/services for which the borrower was allowed to shop and for which the borrower selected a provider not on the SSPL.

Part D – Total Loan Costs (Borrower-Paid)

The bold total on the highlighted line is included in the Closing Costs calculation at the bottom of Page 1.

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Page 2 continued:

Charges/fees appearing in the Other Costs section are for recording fees, prepaid items, initial deposits to an escrow account, and for other products or services that were not required by the lender as a condition of the loan.

Part E – Taxes and Other Government Fees

Recording fees for all documents to be recorded in connection with the transaction. According to the sample, the fees should be separately shown for each document.

Transfer Tax (if applicable) for any taxing entity. If there are multiple entities, separate lines would be used.

Part F – Prepaids On separate lines, each items that must be prepaid, such as interest, hazard insurance premium, mortgage insurance and property taxes.

According to the Blank form and this sample, there is a question as to whether these four items must be shown even when there is no corresponding charge.

Part G – Initial Escrow Payment at Closing

On separate lines, each item for which an initial escrow deposit is required, such as hazard insurance, mortgage insurance, property taxes.

According to the Blank form and this sample, there is a question as to whether these three items must be shown even when there is no corresponding charge.

The last line of this part should be used for the Aggregate Adjustment, if any.

Page 2 continued:

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Part H – Other In this section all charges/fees that do not appear in another section are to be placed, including by way of example:

All fees and charges in connection with a homeowner association.

Fees/charges for any inspections or warranties not required by the lender.

Real estate commissions.

Fees/charges related to owner’s title insurance.

Attorney fees for documents not required by the lender (such as curative documents).

And on and on and on . . . . .

Part I. Total Other Costs (Borrower-Paid)

The bold total on the highlighted line is included in the Closing Costs calculation at the bottom of Page 1.

Important Note: If the fees/charges on page 2 cause the page to exceed the maximum length for printing on letter-size paper, the two sections are to be presented on separate pages numbered Page 2a (for Loan Costs) and Page 2b (for Other Costs).

35



Page 3 has two sections.

The first section, titled CALCULATING CASH TO CLOSE, allows the lender to compare – for the borrower – the same section in the Loan Estimate. For each item, the first column lists the amount disclosed on the Loan Estimate, the second column lists the actual “final” amount for the item; and the last column states whether the amount changed from estimate to final and, if so, gives an explanation of why.

The second section, titled SUMMARIES OF TRANSACTIONS, is very similar to the current Page 1 of a HUD-1 Settlement Statement. Summarizing the transaction for borrower and seller, including charges and credits and the resulting “bottom line” amounts either due by or to the parties.

The top half of the section has charges to the borrower and credits for the seller. Notice that the totals are rolled up to the top lines (K and M), rather than appearing below the listed items.

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Page 3 continued

The bottom half of this section has credits for the borrower and charges to the seller.

On the borrower side of the form, Part L is divided into four separate sections. Notice that the totals are rolled up to the top lines (L and N), rather than appearing below the listed items.

The bottom portion of the section is for a Calculation of the amount of cash that the borrower and seller will either need to bring to closing or will receive from closing.

Notice the “Cash to Close” amount from the borrower is the same as the “Cash to Close” number at the bottom of page 1.

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Page 4: The information will vary based on the terms and conditions of the loan. In order to avoid confusing the borrower, only information that is applicable to the specific loan may be included in the disclosure.

The heading will always be “Additional Information About This Loan

Followed by a sub-heading of Loan Disclosures

The items below the heading and on the left of the page are disclosures – with the appropriate boxes checked indicating:

• Whether the loan can be assumed

• Whether the loan has a demand feature allowing the lender to demand early repayment of the loan

• Information about late payments

• Whether the loan includes a negative amortization feature

• Whether the lender will accept partial payments – payments that are less than the full amount due

• The address of the property put up as collateral for the loan

• And a reminder the borrower may lose the property if payments are not made.

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Page 4 continued:

The heading will always be “Additional Information About This Loan

Followed by a sub-heading of Loan Disclosures

The items below the heading and on the right of the page are disclosures about an escrow account for future payment of taxes and insurance.

If there is an escrow account – top box is checked – the table contains

• An annual estimate for the expenses included in the escrow account.

• An annual estimate for the expenses that are not included in the escrow account.

• The amount of the initial payment into the escrow account – with a reference to Section G on page 2.

• The amount of the monthly escrow that will be included in the monthly payment.

If the second box is checked – one of the following boxes must also be checked to indicate why there is no escrow account.

The table that follows contans:

• An an annual estimate of property costs the borrower will need to pay directly.

• The amount of the Escrow Waiver Fee, if any.

The final paragraph is advice and warnings to the borrower about the type of property costs described above.

The borrower is advised that property costs may change; the borrower may later elect not to escrow.

The borrower is warned about what may happen if the property costs are not paid.

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Page 4 may also have various optional elements.

Either or both of the Adjustable Payment (AP) or Adjustable Interest Rate (AIR) tables may appear at the bottom of page 4, depending on the terms of the specific loan. A table does not appear if the loan does not include the feature. The tables are completed by the lender to provide additional information about the loan to the borrower.

Page 5 always contains four sections: LOAN CALCULATIONS, OTHER DISCLOSURES, QUESTIONS and CONTACT INFORMATION. It may also include a section for the borrower to CONFIRM RECEIPT. If the Confirm Receipt section is not included, following the disclosure from that section is included in the Other Disclosures section: “You do not have to accept this loan because you have received this form or signed a loan application.”

On the left, at the top, are the Loan Calculations. Note: These are from the current Truth-in-Lending.

A total of all payments for the life of the loan.

A total of the finance charge for the life of the loan.

The loan amount.

The Annual Percentage Rate (APR)

The Total Interest Percentage (TIP) – interest paid over the term of the loan expressed as a percent.

The Questions block appears on the left side of the page – near the middle.

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Page 5 – continued. On the right, at the top, are various Other Disclosures. These are not the same on every form.

The disclosure regarding an appraisal is optional and should be included if a new appraisal was a loan requirement.

This disclosure about contract details appears on each form advising the borrower to read the note and deed of trust for information about the loan.

The disclosure about liability after foreclosure appears on each form. One of the boxes will be checked to indicate what liability the borrower may have after the lender forecloses.

This disclosure appears on each form – advising the borrower that a refinance may not be available.

This disclosure appears on each form – advising the borrower to seek tax advice about deductions for interest if the loan amount is greater than the property value.

If the lender does not include the optional Confirm Receipt at the bottom of Page 5, the Loan Acceptance disclosure must be included to advise the borrower he is not obligated to accept the loan just because of the loan application or Closing Disclosure.

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Page 5 – continued. Bottom of the page.

The Contact Information table will be the same on all forms. Only the columns for parties involved with the transaction will be completed. For example, there was no Mortgage Broker for the sample loan, so that column does not contain information.

IMPORTANT: This table requires license numbers for the real estate brokers and real estate agents; and for the settlement agent and the contact at the settlement agent (such as the escrow officer).

The signature section at the bottom of Page 5 is optional. It is up to the lender whether to require the borrower to sign the Closing Disclosure to evidence receipt of the form.

If the Confirm Receipt section is not included, the lender must include the following Loan Acceptance Disclosure under Other Disclosures: “You do not have to accept this loan because you have received this form or signed a loan application.”

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Closing Disclosure: A Line by Line Look


Page 1 – Closing Information

43


Page 1 – Loan Terms


Page 1 – Projected Payments

44


Page 1 – Costs at Closing


Page 2 – Closing Cost Details –Loan Costs

45


Page 2 – Closing Cost Details –Other Costs


Page 3 – Calculating Cash to Close

46


Page 3 – Summaries of Transactions


Page 3 – Summaries continued

47


Page 4 – Left Frame


Page 4 – Right Frame

48


Page 4 – Optional Disclosures


Page 5 – Loan Calculations

49


Page 5 – Questions?


Page 5 – Other Disclosures

50


Page 5 – Contact Information


Page 5 – Optional Confirm Receipt

51


Changing Roles, Responsibilities and Processes

Presented by

Teresa Frost, CTIA National Investors Title Insurance Company

Denise Holmes Independence Title Company

Dawn Marie Lewallen Stewart Title Guaranty Company

Marvin Stone Stewart Lender Services

53



Changing Roles and Responsibilities

I. Who Provides Disclosure?

A. Loan Estimate to consumer – either Creditor or Loan Broker may prepare and provide

• Creditor still liable/responsible

B. Closing Disclosure to consumer – either Creditor or Settlement Agent may prepare and provide

• Creditor still liable/responsible

C. Closing Disclosure to Seller – Settlement Agent must prepare and provide

II. Continued Uncertainty about Who Will Do What • CFPB holds the creditor responsible for the Closing Disclosure

• Lenders will decide what role settlement agents will play

• Not all lenders will make the same decision – resulting in a mix of disclosure scenarios – so settlement agents will need to be nimble

Notes: • Wells Fargo and Bank of America have publicly announced they will prepare and

distribute the Closing Disclosure. • It is rumored that CitiMortgage will soon make a similar announcement.

A. Information Flow The lender will need about the same information about fees/charges before

delivering the Loan Estimate as they now need before delivering a GFE

If the lender prepares the Closing Disclosure, it will need from the settlement agent

Complete and accurate detail of all fees and charges, not just those related to the loan or included in the LE

If the settlement agent prepares the Closing Disclosure, it will need from the lender

A complete copy of the LE and SSPL

Detailed final loan and lender fee information.

Exchange of information may be hampered by the lack of uniform “names” for various fees and charges.

Exchange of information may benefit from loan and settlement technology platforms that integrate or talk with one another to eliminate redundant keying of information.

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TRID – Changing Roles and Responsibilities


B. A Few Words about Integration

Because the new Closing Disclosure will require more collaboration between parties, several lenders are moving to an integration-only model for both refinance and purchase transactions. This means lender and settlement agent both need to integrate core systems to a third-party exchange like RealEC or use a “portal” where they can key the data, upload documents and report events as they occur.

While time and cost are involved in developing integration, including possible per-transaction charges, the idea is that both lender and settlement provider will benefit from the elimination of rekeying and “mis-keying” as well as potentially eliminating use of phone, fax and e-mail.

That being said, the problem that arises with integration is that you could potentially have a process for “traditional” orders and a separate, new process for “integrated” orders.

There are really three main parts to any integration:

• Data, such as borrower info, loan info, transaction info and fees.

• Documents, such as the commitment, fee sheets, tax certifications.

• Events such as signaling to the lender that the order has been received, the commitment has been delivered, the signing has been scheduled, etc.

III. Scheduling Closings

A. Possible Process – Lender Prepares Closing Disclosure

1. Loan is approved – lender contacts settlement agent to schedule closing – giving a “no sooner than” date.

• Not less than 7 days after delivery of the initial LE

• Not less than 3 days (or 6 days depending on lender) after anticipated receipt by borrower of the CD

2. Settlement agent contacts parties; a date is selected and confirmed with all parties.

3. Settlement agent contacts lender to give scheduled closing date and details of all fees, charges and credits for settlement of the real estate transaction.

• Although seller disclosure is not delivered until closing, a best practice would be to wait to schedule closing until all fees/charges are known, including repair invoices, curative matters and payoff calculations, etc.

4. Lender prepares CD and delivers to borrower with a copy to settlement agent.

• Lender may also deliver lender instructions and documents to be recorded – or may elect to deliver full loan package to settlement agent

5. Settlement agent reviews CD and verifies accuracy of fees/charges/credits related to settlement of real estate transaction.

• If there are inaccuracies – settlement agent immediately notifies lender.

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• If changes are needed before closing – settlement agent or lender prepares new CD and notifies borrower that it is available for review no later than the day before closing.

6. Settlement agent finalizes Seller’s Disclosure.

• Settlement agent may deliver Seller’s Disclosure to seller and listing agent in advance of closing.

7. At closing, settlement agent:

• Obtains signature from borrower on some type of settlement authorization (since the closing disclosure does not provide for signature or authority to proceed)

• Delivers Seller Disclosure to seller and obtains signature from seller on some type of settlement authorization (same reason as for borrower).

B. Possible Process –Settlement Agent Prepares Closing Disclosure

1. Loan is approved – lender contacts settlement agent to schedule closing – giving a “no sooner than” date.

• Not less than 7 days after delivery of the initial LE

• Not less than 3 days (or 6 days depending on lender) after anticipated receipt by borrower of the CD

2. Settlement agent contacts parties; a date is selected and confirmed with all parties.

3. Settlement agent contacts lender to give scheduled closing date and request details of the loan and all lender fees/charges.

• Lender may also deliver lender instructions and documents to be recorded – or may elect to deliver full loan package to settlement agent

• Although seller disclosure is not delivered until closing, a best practice would be to wait to schedule closing until all fees/charges are known, including repair invoices, curative matters and payoff calculations, etc.

4. Settlement Agent prepares CD and delivers to borrower with a copy to lender.

5. Lender reviews CD and verifies accuracy of loan information and lender fees/charges.

• If there are inaccuracies – lender notifies settlement agent.

• If changes are needed before closing – settlement agent or lender prepares new CD and notifies borrower that it is available for review no later than the day before closing.

6. Settlement agent finalizes Seller’s Disclosure.

• Settlement agent may deliver Seller’s Disclosure to seller and listing agent in advance of closing.

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7. At closing, settlement agent:

• Obtains signature from borrower on some type of settlement authorization (since the closing disclosure does not provide for signature or authority to proceed)

• Delivers Seller Disclosure to seller and obtains signature from seller on some type of settlement authorization (same reason as for borrower).

Note: TLTA is currently working with TDI toward a promulgated Texas Disclosure form to provide correct premiums to the consumer and seller, as well as to make other required Texas disclosures – and to provide for seller and consumer signatures to authorize disbursement.

C. Let’s talk about other possibilities and possible scenarios

58


Changing Roles and Responsibilities


Who Provides Disclosures?

• Loan Estimate to consumer

– Creditor or Loan Broker


• Closing Disclosure to consumer

– Creditor or Settlement Agent


• Closing Disclosure to seller

– Settlement Agent

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Who Will Do What?

• CFPB holds lender responsible

• Lenders will decide what role settlement agents will play

• Not all lenders will make the same decision

– Result will be a mix of disclosure scenarios

– Settlement agents must be nimble


Information Flow

• Loan Estimate about the same as for GFE

• IF Lender prepares Closing Disclosure– Contract regarding who pays what, credits, etc.

– Info for prorations/adjustments between seller/buyer

– Complete and accurate detail about all fees and charges –not just those related to the loan

• IF Settlement Agent prepares Closing Disclosure– Copy of Loan Estimate and Service Provider List

– Detailed final loan and lender fee information

• Hindered by lack of uniform “names” for fees

• Benefited by possible electronic exchange of info

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Integration

• New forms require more collaboration between parties.

• Several lenders have announced they will require settlement agents to participate in using third‐party exchanges, like RealEC – or other data exchanges solutions.

• An integration consists of:

– Data

– Documents

– Events


Technology Concerns

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Scheduling Closings – Etc.

• Loan approved – lender contacts settlement agent– Closing no sooner than _______

• Settlement agent schedules closing & tells lender• Settlement agent & lender exchange information

– Not sure yet how this will work

• Settlement agent and/or lender prepare CD• Lender delivers CD to buyer and settlement agent• Settlement reviews CD for accuracy

– As to proper settlement of the real estate transaction– Advises lender if CD is not accurate

• Someone revises and advises borrower• Must be available for review day before consummation

• Settlement agent prepares Seller Disclosure• At closing

– Settlement agent obtains signatures from borrower and seller on something to approve receipts & disbursements and to authorize funding


Let’s Talk About Other Scenarios

62


New Timelines from Loan Approval

to Closing

Presented by

Denise Holmes Independence Title Company

63



Timeline Examples

For the purpose of the Closing Disclosure, business day means all calendar days except Sundays and legal public holidays specified in 5 U.S.C. 6103(a) such as, New Year’s Day, the Birthday of Martin Luther King, Jr., Washington’s Birthday, Memorial Day, Independence Day, Labor Day, Columbus Day, Veterans Day, Thanksgiving Day, and Christmas Day.

According to the Consumer Financial Protection Bureau’s final rule, the borrower must receive the Closing Disclosure at least three business days prior to closing.

If the Closing Disclosure is mailed (or emailed) to the borrower and the borrower doesn’t actually physically acknowledge receipt, the lender may presume receipt by the borrower three days after it is put in the mail or sent via email (the mailbox rule).

If changes occur affecting the Closing Disclosure in any of the following three ways, a revised CD must be received by the borrower at least three business days prior to closing – in other words, there is a new 3-day waiting period:

• APR changes by more than 1/8 of 1% • A pre-payment penalty is added • The loan product is changed.

For any other changes, a revised CD must be delivered to the borrower no later than closing; however, upon request the borrower must be allowed to view the CD the day before closing.

Example

Monday • Loan is approved

• Closing is scheduled

• Lender and settlement agent coordinate and exchange all fees and charges.

• Closing Disclosure is emailed to the borrower with no request for acknowledgment.

Tuesday

Wednesday

Thursday Borrower is presumed to have received Closing Disclosure

Friday

Saturday (Saturday is counted as a business day)

Monday Loan can now close.

.

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TRID – Timeline Examples


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http://altaonline.typepad.com/.a/6a0192ac343706970d01a511f09ef2970c-pi


Closing Disclosure Timeline


Closing Disclosure Timeline

• Business day for purposes of the Closing Disclosure

all calendar days

except Sundays and legal public holidays

HOLIDAYS

New Year’s Day Labor Day

Birthday of Martin Luther King, Jr. Columbus Day

Washington’s Birthday Veterans Day

Memorial Day Thanksgiving Day

Independence Day Christmas Day

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Receipt of Closing Disclosure

• Borrower must receive at least three (3) business days prior to closing

• If the Closing Disclosure is mailed (or emailed) to the borrower, the lender may presume receipt by the borrower three days after it is put in the mail or sent via email (the mailbox rule).


Changes That Affect the Closing Disclosure

• The following changes require a new 3‐day waiting period

APR changes by more than 1/8 of 1%

A pre‐payment penalty is added

The loan product is changed

• For any other changes, a revised CD must be delivered to the borrower no later than closing

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Timeline Example

• MONDAY: Loan is approved Closing is scheduled Lender and settlement agent coordinate and exchange all

fees and charges Closing Disclosure is emailed to the borrower with no

request for acknowledgment

• THURSDAY Borrower is presumed to have received Closing Disclosure

• MONDAY Loan can now close


Three Day Closing Disclosure Rule

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Three Day Closing Disclosure Rule ‐ Timeline– From When Closing Disclosure is Mailed

Mail Disclosure

Monday Tuesday Wednesday Thursday Friday Saturday

Disclosure Presumed Received

Thursday Friday Saturday Monday Tuesday Wednesday

Closing Date

Following Monday

Following Tuesday

Following Wednesday

Following Thursday

Following Friday

Following Saturday


Three Day Closing Disclosure Rule

• If a federal holiday falls in the 3‐day period, add a day for disclosure delivery

• 3‐day period in measured in days, not in hours

• Closing Disclosure may be delivered electronically on due date in compliance with E‐sign requirements

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Top 10 Things

You Should Know

71



Ten Things You Should Know

I. TOP 10 THINGS A SETTLEMENT AGENT NEEDS TO KNOW ABOUT TRID 1. What happens on August 1, 2015?

• The new Integrated Disclosures (LE and CD) must be provided for loan applications received on or after August 1, 2015 on closed-end consumer credit transactions (excluding reverse mortgages) secured by real property

2. Do I still need to know how to prepare a GFE (lender) and HUD-1 (settlement agent)?

• Yes. Reverse Mortgages still fall under the old RESPA rules and are not subject to the new TRID requirements.

3. Who is most likely to prepare the initial Closing Disclosure – and why?

• The lender – because the lender is held responsible for accuracy and delivery.

4. What if the Closing Disclosure is “inaccurate”? Who is likely to prepare a revised Closing Disclosure (if necessary) – when and why?

• The revised CD will most likely be prepared by the same party who prepared the initial CD.

• The revised CD must be available for the borrower to review no later than the day before closing, but it may be delivered to the borrower at the closing table.

5. Who prepares and delivers a Closing Disclosure to the Seller? How far in advance of closing must the seller receive the disclosure?

• The Settlement Agent is responsible for preparing and delivering the CD to the Seller.

• The seller must receive no later than closing.

6. How are simultaneous-issue owner’s and loan policy premiums disclosed on the Loan Estimate and Closing Disclosure?

• The full Basic Rate for a loan policy is collected from the borrower. The premium for the owner’s policy – also collected from the borrower – is calculated by taking the full Basic Rate for the owner’s policy, plus the rate for a simultaneous loan policy (usually $100), minus the full Basic Rate for the loan policy.

• For example, if the sales price is $180,000 and the loan amount is $162,000 – the loan policy premium will be disclosed as $1,218.00 and the owner’s policy premium will be disclosed as $200.00

a. Why is it a problem in Texas (and many other states)?

o Because in Texas – and many other states – the discounted policy in a simultaneous-issue transaction is given on the loan policy, not the owner’s policy.

o In the example, the actual promulgated premiums are $100 for the loan policy and $1,318 for the owner’s policy.

73

TRID – Ten Things to Know


b. Does the lender violate the allowable variance if there is no disclosure of an optional owner’s policy on the Loan Estimate?

o In the rule and commentary, the owner’s policy is specifically excluded from variance/tolerance, so long as the original estimated charge, or lack of an estimated charge, was based on the best information reasonably available to the creditor at the time the disclosure was provided.

7. How do I disclose the agent and underwriter portions of the premium – I don’t see anything about that on the Closing Disclosure?

• The Closing Disclosure is a Federal disclosure form and does not provide for state-specific disclosures.

• TLTA is working with TDI to promulgate a Texas Disclosure to be used with the CD.

8. It looks like there may be more fees than there are lines in some of the sections on Page 2 – what happens if there isn’t room to itemize all the fees?

• If Page 2 does not provide enough lines for all fees/charges, it is broken out into two pages, one for Loan Costs (Page 2a) and another for Other Costs (Page 2b).

9. If the settlement agent is affiliated with the lender, does it make a difference in regard to how much variance is allowed between the Loan Estimate and the Closing Disclosure?

• Yes, under the new rules, fees/charges by settlement providers who are affiliated with the lender are placed into the “zero tolerance” category for variations between the Loan Estimate and the Closing Disclosure, not the 10% tolerance category.

10. After a loan is finally approved, how soon can we realistically expect to close the transaction?

• No sooner than the third “business day” (doesn’t include Sundays or Federal holidays) after approval – provided on the day of approval the lender (or settlement agent) prepares and delivers the Closing Disclosure and the borrower affirmatively acknowledges receipt on that day.

Note: This contemplates the borrower previously received the LE, since the LE and CD cannot be delivered on the same day.

• For lenders who rely on the “mail-box rule,” or presumption of receipt three business days after delivery, the closing may be no sooner than the sixth business day after approval – provided on the day of approval the lender (or settlement agent) prepares and delivers the Closing Disclosure on that day.

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TRID – Ten Things to Know


II. Want to know more?

A. Go to the CFPB website:

http://www.consumerfinance.gov/regulatory-implementation/tila-respa/

B. Sign up to receive news.

C. Browse through the training aids – links to recorded webinars (Videos) – sample forms – the regulations – and more . . . .

D. New items added on a regular basis – so check back often.

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http://www.consumerfinance.gov/regulatory-implementation/tila-respa/