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RESPA Update RESPA Update

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34
3/29/2011









RESPA Update

Florida Bankers Association

April 6 - 8, 2011





1









RESPA Update



I. Transitional Period



II. Current Experience with Requirements



III. RESPA Reform Changes







2









1

3/29/2011









RESPA Update

• Transitional Period

– Dodd/Frank - Section 1032(f) of the Act, the

new Bureau of CFPA is required to propose a

single integrated model disclosure that

combines TILA/Reg Z disclosures with

RESPA/Reg X (GFE) disclosures

Within One Y ft d i t d transfer

– Withi O Year after designated t f

date – unless Board & HUD issue proposal

first



3









RESPA Update

• Transitional Period

– Combined disclosure concept was original

intent of Congress

– HUD has ceased updating its FAQ’s since

4/2/10 regarding RESPA Reform changes

– Many of the burdens of the current 3 page

disclosure format will go away?







4









2

3/29/2011









RESPA Update

• Current Large & Community Bank

Experience



– Multiple GFE disclosures provided because of

“changed circumstances” as many as six

times before closing

– Dates for guaranteeing GFE charges

extended from original issuance date

– Cover letters to consumers alerted consumers

to changes but not specifics that caused

changes

5









RESPA Update

• Current Large & Community Bank

Experience



– Confusion regarding completion of revised

GFE disclosures (“changed circumstance”)



– Isolated violations with regard to 3 business

day rule (based on days open for business

count) for delivery of GFE disclosures



– Other comments? 6









3

3/29/2011









RESPA REFORM



Rule to Simplify and Improve the

Process of Obtaining Mortgages &

Reduce Consumer Settlement Costs





September 2009 7









Background

• 2008 HUD issued a proposal to improve transparency

in settlement procedures and to help consumers

compare the prices of mortgage loans and related

settlement services



• Along the way HUD met resistance from the industry and

even the House of Representatives urged HUD to

reconsider and withdraw its proposal and to work with

h hil it d i

the FED while i modernizes R l i

Regulation Z



• October 13, 2009 Trade Association Letter (32 pages)

requesting delay

8









4

3/29/2011









Background

• Common theme to both the new GFE disclosures and

timing rules imposed by Reg X and Reg Z (MDIA):



• Provide disclosures in a timely manner so as to allow

consumers to:



1) shop & compare loan transactions among lenders



Provide i f ti for to:

• P id information f consumers t



2) understand terms and conditions of the

transaction they are about to

9









Background

• Some definitions have changed and some have been

added to Regulation X –



– Application

– Changed Circumstances

– Mortgage Broker

– Origination Service

– Tolerance

– Required Use





10









5

3/29/2011









Background

• New GFE & HUD 1 work in tandem to provide more

meaningful disclosures on the front end during the

application shopping process



• The GFE has taken a turn to become a firmer and more

binding disclosure as originators must stand behind their

disclosures for a 10 day period



• GFE is now subject to tolerances







11









Background

• GFE & HUD 1 designed for the consumer to review early

side by side

estimates side-by-side at the closing with actual costs for

services



• No civil liability but “right to cure” violations hangs over

originators as a reminder to make correct disclosures



• Important to note that RESPA Reform did not overhaul

RESPA, it only revised certain parts of it

– E.g. Coverage of RESPA was not expanded and exempt

transactions remain unchanged



12









6

3/29/2011









RESPA REFORM

Final Rule









13









RESPA’s Final Rule

• RESPA’s Final Rule was published in the

November 17, 2008 Federal Register

g



• It’s effective date was split into two parts:

– Some changes went into effect this past

January 16, 2009



– More significant changes are scheduled for

January 1, 2010

September 2009 14









7

3/29/2011









RESPA’s Final Rule



p g

• Recap of 2009 Changes:



– Section 3500.21 of Regulation X (Mortgage

Servicing Transfer Disclosure) revised



• Estimates eliminated

• Written acknowledgement eliminated



– See Appendix MS-1 model form



September 2009 15









Servicing

Disclosure

Di l

Statement

Appendix

MS-1

MS 1







16









8

3/29/2011









RESPA REFORM

Recap of 2009 Changes:



• New Section 3500.23 (ESIGN)



• Regulation X is amended to recognize the statutory

applicability of the Electronic Signatures in Global and

National Commerce Act (ESIGN) to RESPA



• All RESPA disclosures may be provided in electronic

form, if consumer provides consent and compliance with

E-Sign is met

17









RESPA REFORM

• Recap of 2009 Changes:



• New Section 3500.23 (ESIGN)



• Retention of documents are permitted to be in electronic

format consistent with ESIGN requirements (Section

101)which must be met









18









9

3/29/2011









RESPA REFORM

• Recap of 2009 Changes:



• New Section: 3500.22 (Severability)



• If a court strikes down a particular requirement in a case,

other requirements still apply









19









RESPA’s Final Rule

• Recap of 2009 Changes:



• Average Charges (added as option)



• HUD now allows use of charges for third party services

to be computed based on average cost mechanisms



• Settlement service provider must recalculate the average

charge at least every 6 months



20









10

3/29/2011









RESPA’s Final Rule

– Recap of 2009 Changes:



– Technical changes to Section 3500.17 &

Appendix E regarding arithmetic steps for

Escrow Analysis



q

– “Required Use” definition was revised to

revoke a builder’s Section 8 exemption –

change was withdrawn in May 2009





21









RESPA REFORM

• January 1, 2010 Changes:



• Amend RESPA’s core disclosure forms:

– Good Faith Estimate (GFE)

– HUD-1/HUD-1A Settlement Statements



• Restructure them in form and substance to facilitate

shopping and improve comparison among the forms at

closing



September 2009 22









11

3/29/2011









RESPA’s Final Rule

• Other 2010 Changes:

• Application – New definition

– Means the submission of a borrower’s financial

information i anticipation of a credit d i i

i f ti in ti i ti f An

dit decision. A

application may either be in writing or electronically

submitted, including a written record of an oral

application

– Content – would contain 6 items:

1.Borrower’s name

2.SS # for credit report

3.Monthly income

4.Property address

5.Estimated value of the property

6.Loan amount

*Originators may ask for additional information beyond these 6 items

September 2009 23









RESPA’s Final Rule

• Other 2010 Changes:

• NEW Settlement Cost Booklet

– Revised January 6, 2010

– Changes technical

– Last revised September 1997

• Previous Rules Apply

– Provide for Purchase-money application

– Three-day timing requirement

24









12

3/29/2011









Revised Settlement Cost

Booklet 1-06-10









25









NEW

Good Faith Estimate

Form









26









13

3/29/2011









GFE

Page 1





27









Important Dates









28









14

3/29/2011









Summary of your loan









29









Escrow Account Information









September 2009 30









15

3/29/2011









Summary of Your Settlement Charges









September 2009 31









GFE

Page 2





32









16

3/29/2011









GFE

Page 3

Instruction







33









Which Charges Can Increase









34









17

3/29/2011









Tradeoff table









35









Shopping Chart









36









18

3/29/2011









Right-to-Cure





Charges exceeding tolerance

not a violation of RESPA Section 5

IF borrower is reimbursed within

30 calendar days after settlement and

receives new disclsoure





September 2009 37









New vs. Old GFE F

N Form



Comparisons







38









19

3/29/2011









New vs. Old GFE Form

• No more range of estimates

New GFE aggregates fees

• N t f

• Section 3500.7(e) – Required Service Provider

disclosures eliminated

• Section 1300 “Additional Settlement Charges”

no longer used – GFE only discloses

h /f

charges/fees

• New Appendix C of Regulation X provides

instructions for completion of the GFE



September 2009 39









New

HUD 1 Settlement Statement

Form







40









20

3/29/2011









HUD-1

Settlement

Statement







September 2009 41









HUD 1

HUD-1-

Page 2







September 2009 42









21

3/29/2011









HUD-1-

Page 3





43









Comparison

Chart









44









22

3/29/2011









Loan

Terms







45









In General



Inadvertent or technical errors not a

violation of RESPA Section 4 IF revised

HUD-1 is provided within 30 calendar

days after settlement







September 2009 46









23

3/29/2011









Some Old Rules for HUD 1 Still

Apply

• Still show “ultimate recipients” of fees

• Fees paid to different service providers

should not be combined

• 5 year retention of the statement unless

loan is sold

• No fees allowed for preparation or

distribution of HUD 1, Escrow Account

Statements or TIL Statement

September 2009 47









Similarities Between MDIA &

RESPA Rules

• No fees (other than reasonable & bona

fide credit report fee) may be imposed until

consumer has received both GFE & Early

TIL

• 3 Business Day Presumption Rule applies

when both disclosures are mailed (must

refrain from imposing other fees during

this period)

48









24

3/29/2011









Similarities Between MDIA &

RESPA Rules

y

• Both GFE & Early TIL must be p provided

within 3 business days (using “open for

business day count”) unless loan will be

denied or withdrawn



• RESPA’s definition of Application serve’s

as a trigger for providing both GFE & Early

TIL

August 2009 49









New RESPA Examination

Procedures

• CA Letter 09-11

• Become Effective 01/01/10

• Includes technical amendments that

became effective 01/16/09

• Also, substantive changes that become

g

effective 01/01/10





50









25

3/29/2011









RESPA Exam Procedures

Checklist Questions New Procedures

• Policies/Operating • GFE form, delivery,

Procedures/Training contents, completion

• Special Information • HUD 1 form, old & new

Booklet rules

• Good Faith Estimate • Right to cure violations

• Affiliated Business

Arrangement Discl.

• HUD 1 Statement





51









RESPA Exam Procedures

Checklist Questions New Procedures

• Mortgage Serving • Revised Form

Transfer Disclosure • ESIGN

• Hello – Good Bye Letters

• Escrow Rules,

Disclosures, Limitations,

Prohibitions

• No fees for RESPA

disclosures

• Section 8 - Kickback



52









26

3/29/2011









Questions







• Thanks for your time!!!









September 2009 53









27

OMB Approval No. 2502-0265



A. Settlement Statement (HUD-1)



B. Type of Loan

6. File Number: 7. Loan Number: 8. Mortgage Insurance Case Number:

1. FHA 2. RHS 3. Conv. Unins.



4. VA 5. Conv. Ins.



C. Note: This form is furnished to give you a statement of actual settlement costs. Amounts paid to and by the settlement agent are shown. Items marked

“(p.o.c.)“ were paid outside the closing; they are shown here for informational purposes and are not included in the totals.



D. Name & Address of Borrower: E. Name & Address of Seller: F. Name & Address of Lender:









G. Property Location: H. Settlement Agent: I. Settlement Date:





Place of Settlement:









J. Summary of Borrower’s Transaction K. Summary of Seller’s Transaction



100. Gross Amount Due from Borrower 400. Gross Amount Due to Seller

101. Contract sales price 401. Contract sales price

102. Personal property 402. Personal property

103. Settlement charges to borrower (line 1400) 403.

104. 404.

105. 405.

Adjustment for items paid by seller in advance Adjustments for items paid by seller in advance

106. City/town taxes to 406. City/town taxes to

107. County taxes to 407. County taxes to

108. Assessments to 408. Assessments to

109. 409.

110. 410.

111. 411.

112. 412.



120. Gross Amount Due from Borrower 420. Gross Amount Due to Seller

200. Amounts Paid by or in Behalf of Borrower 500. Reductions In Amount Due to Seller

201. Deposit or earnest money 501. Excess deposit (see instructions)

202. Principal amount of new loan(s) 502. Settlement charges to seller (line 1400)

203. Existing loan(s) taken subject to 503. Existing loan(s) taken subject to

204. 504. Payoff of first mortgage loan

205. 505. Payoff of second mortgage loan

206. 506.

207. 507.

208. 508.

209. 509.

Adjustments for items unpaid by seller Adjustments for items unpaid by seller

210. City/town taxes to 510. City/town taxes to

211. County taxes to 511. County taxes to

212. Assessments to 512. Assessments to

213. 513.

214. 514.

215. 515.

216. 516.

217. 517.

218. 518.

219. 519.



220. Total Paid by/for Borrower 520. Total Reduction Amount Due Seller

300. Cash at Settlement from/to Borrower 600. Cash at Settlement to/from Seller

301. Gross amount due from borrower (line 120) 601. Gross amount due to seller (line 420)

302. Less amounts paid by/for borrower (line 220) ( ) 602. Less reductions in amount due seller (line 520) ( )



303. Cash From To Borrower 603. Cash To From Seller









The Public Reporting Burden for this collection of information is estimated at 35 minutes per response for collecting, reviewing, and

reporting the data. This agency may not collect this information, and you are not required to complete this form, unless it displays a

currently valid OMB control number. No confidentiality is assured; this disclosure is mandatory. This is designed to provide the parties to

a RESPA covered transaction with information during the settlement process.









Previous editions are obsolete Page 1 of 3 HUD-1

L. Settlement Charges



700. Total Real Estate Broker Fees Paid From Paid From

Division of commission (line 700) as follows: Borrower’s Seller’s

Funds at Funds at

701. $ to Settlement Settlement

702. $ to

703. Commission paid at settlement

704.



800. Items Payable in Connection with Loan

801. Our origination charge $ (from GFE #1)

802. Your credit or charge (points) for the specific interest rate chosen $ (from GFE #2)

803. Your adjusted origination charges (from GFE A)

804. Appraisal fee to (from GFE #3)

805. Credit report to (from GFE #3)

806. Tax service to (from GFE #3)

807. Flood certification (from GFE #3)

808.



900. Items Required by Lender to Be Paid in Advance

901. Daily interest charges from to @$ /day (from GFE #10)

902. Mortgage insurance premium for months to (from GFE #3)

903. Homeowner’s insurance for years to (from GFE #11)

904.



1000. Reserves Deposited with Lender

1001. Initial deposit for your escrow account (from GFE #9)

1002. Homeowner’s insurance months @ $ per month $

1003. Mortgage insurance months @ $ per month $

1004. Property taxes months @ $ per month $

1005. months @ $ per month $

1006. months @ $ per month $

1007. Aggregate Adjustment –$



1100. Title Charges

1101. Title services and lender’s title insurance (from GFE #4)

1102. Settlement or closing fee $

1103. Owner’s title insurance (from GFE #5)

1104. Lender’s title insurance $

1105. Lender’s title policy limit $

1106. Owner’s title policy limit $

1107. Agent’s portion of the total title insurance premium $

1108. Underwriter’s portion of the total title insurance premium $



1200. Government Recording and Transfer Charges

1201. Government recording charges (from GFE #7)

1202. Deed $ Mortgage $ Releases $

1203. Transfer taxes (from GFE #8)

1204. City/County tax/stamps Deed $ Mortgage $

1205. State tax/stamps Deed $ Mortgage $

1206.



1300. Additional Settlement Charges

1301. Required services that you can shop for (from GFE #6)

1302. $

1303. $

1304.

1305.



1400. Total Settlement Charges (enter on lines 103, Section J and 502, Section K)









Previous editions are obsolete Page 2 of 3 HUD-1

Comparison of Good Faith Estimate (GFE) and HUD-1 Charges Good Faith Estimate HUD-1

Charges That Cannot Increase HUD-1 Line Number

Our origination charge # 801

Your credit or charge (points) for the specific interest rate chosen # 802

Your adjusted origination charges # 803

Transfer taxes #1203





Charges That in Total Cannot Increase More Than 10% Good Faith Estimate HUD-1

Government recording charges # 1201

#1201

#1201

#1201

#1201

#1201

#1201

#____



Total

Increase between GFE and HUD-1 Charges $123456 or %







Charges That Can Change Good Faith Estimate HUD-1

Initial deposit for your escrow account #1001

Daily interest charges # 901 $ 2 /day

Homeowner’s insurance # 903

#1201

#1201

#1201







Loan Terms

Your initial loan amount is $



Your loan term is years



Your initial interest rate is %



Your initial monthly amount owed for principal, interest, and $ includes

and any mortgage insurance is Principal

Interest

Mortgage Insurance



Can your interest rate rise? No. Yes, it can rise to a maximum of XXX%. The first change will be

on [DATEDATE] and can change again every [DATEDATE] after

[DATEDATE] . Every change date, your interest rate can increase or decrease

by XXX%. Over the life of the loan, your interest rate is guaranteed to never be

lower than XXX% or higher than XXX%.



Even if you make payments on time, can your loan balance rise? No. Yes, it can rise to a maximum of $[AMOUNT].



Even if you make payments on time, can your monthly No. Yes, the first increase can be on and the monthly amount

amount owed for principal, interest, and mortgage insurance rise? owed can rise to $[DATEDATE].

The maximum it can ever rise to is $[DATEDATE].



Does your loan have a prepayment penalty? No. Yes, your maximum prepayment penalty is $[AMOUNT .



Does your loan have a balloon payment? No. Yes, you have a balloon payment of $[AMOUNT] due in

XXX years on [DATEDATE].



Total monthly amount owed including escrow account payments You do not have a monthly escrow payment for items, such as property

taxes and homeowner’s insurance. You must pay these items directly yourself.



You have an additional monthly escrow payment of $[AMOUNT]

that results in a total initial monthly amount owed of $[AMOUNT]. This includes

principal, interest, any mortgage insurance and any items checked below:

Property taxes Homeowner’s insurance

Flood insurance







Note: If you have any questions about the Settlement Charges and Loan Terms listed on this form, please contact your lender.





Previous editions are obsolete Page 3 of 3 HUD-1

OMB Approval No. 2502-0265





Good Faith Estimate (GFE)





Name of Originator Borrower

Originator

Address

Property

Address

Originator Phone Number



Originator Email Date of GFE







Purpose This GFE gives you an estimate of your settlement charges and loan terms if you are approved for this loan.

For more information, see HUD’s Special Information Booklet on settlement charges, your Truth-in-Lending

Disclosures, and other consumer information at www.hud.gov/respa. If you decide you would like to proceed

with this loan, contact us.



Shopping for Only you can shop for the best loan for you. Compare this GFE with other loan offers, so you can find the best

your loan loan. Use the shopping chart on page 3 to compare all the offers you receive.



Important dates 1. The interest rate for this GFE is available through . After this time, the interest

rate, some of your loan Origination Charges, and the monthly payment shown below can change until you

lock your interest rate.

2. This estimate for all other settlement charges is available through .

3. After you lock your interest rate, you must go to settlement within days (your rate lock

period) to receive the locked interest rate.

4. You must lock the interest rate at least days before settlement.



Summary of Your initial loan amount is $

your loan Your loan term is years

Your initial interest rate is %

Your initial monthly amount owed for principal,

interest, and any mortgage insurance is $ per month

Can your interest rate rise? c No c Yes, it can rise to a maximum of %.

The first change will be in

Even if you make payments on time, can your c No c Yes, it can rise to a maximum of $

loan balance rise?

Even if you make payments on time, can your c No c Yes, the first increase can be in

monthly amount owed for principal, interest, and the monthly amount owed can

and any mortgage insurance rise? rise to $ . The maximum

it can ever rise to is $ .

Does your loan have a prepayment penalty? c No c Yes, your maximum prepayment

penalty is $

Does your loan have a balloon payment? c No c Yes, you have a balloon payment of

$ due in years.

Escrow Some lenders require an escrow account to hold funds for paying property taxes or other property-related

account charges in addition to your monthly amount owed of $ .

information Do we require you to have an escrow account for your loan?

c No, you do not have an escrow account. You must pay these charges directly when due.

c Yes, you have an escrow account. It may or may not cover all of these charges. Ask us.



Summary of

your A Your Adjusted Origination Charges (See page 2.) $



settlement B Your Charges for All Other Settlement Services (See page 2.) $

charges

A + B Total Estimated Settlement Charges $



Good Faith Estimate (HUD-GFE) 1

Understanding Your Adjusted Origination Charges

your estimated

1. Our origination charge

settlement This charge is for getting this loan for you.

charges 2. Your credit or charge (points) for the specific interest rate chosen

c The credit or charge for the interest rate of % is included in

“Our origination charge.” (See item 1 above.)

c You receive a credit of $ for this interest rate of %.

This credit reduces your settlement charges.

c You pay a charge of $ for this interest rate of %.

This charge (points) increases your total settlement charges.

The tradeoff table on page 3 shows that you can change your total settlement charges by

choosing a different interest rate for this loan.



A Your Adjusted Origination Charges $



Your Charges for All Other Settlement Services



Some of these 3. Required services that we select

These charges are for services we require to complete your settlement. We will choose the

charges providers of these services.

can change Service Charge

at settlement.

See the top of

page 3 for more

information.



4. Title services and lender’s title insurance

This charge includes the services of a title or settlement agent, for example, and title insurance

to protect the lender, if required.

5. Owner’s title insurance

You may purchase an owner’s title insurance policy to protect your interest in the property.

6. Required services that you can shop for

These charges are for other services that are required to complete your settlement. We can

identify providers of these services or you can shop for them yourself. Our estimates for

providing these services are below.

Service Charge









7. Government recording charges

These charges are for state and local fees to record your loan and title documents.

8. Transfer taxes

These charges are for state and local fees on mortgages and home sales.

9. Initial deposit for your escrow account

This charge is held in an escrow account to pay future recurring charges on your property and

includes all property taxes, all insurance, and other .

10. Daily interest charges

This charge is for the daily interest on your loan from the day of your settlement until the first day

of the next month or the first day of your normal mortgage payment cycle.

This amount is $ per day for days (if your settlement is ).

11. Homeowner’s insurance

This charge is for the insurance you must buy for the property to protect from a loss, such as fire.

Policy Charge









B Your Charges for All Other Settlement Services $





A + B Total Estimated Settlement Charges $









Good Faith Estimate (HUD-GFE) 2

Instructions

Understanding This GFE estimates your settlement charges. At your settlement, you will receive a HUD-1, a form that lists your

which charges actual costs. Compare the charges on the HUD-1 with the charges on this GFE. Charges can change if you select

your own provider and do not use the companies we identify. (See below for details.)

can change at

These charges The total of these charges These charges

settlement cannot increase can increase up to 10% can change

at settlement: at settlement: at settlement:

Our origination charge Required services that we select Required services that you can

shop for (if you do not use companies

Your credit or charge (points) for Title services and lender’s title we identify)

the specific interest rate chosen insurance (if we select them or

(after you lock in your interest rate) you use companies we identify) Title services and lender’s title

insurance (if you do not use

Your adjusted origination charges Owner’s title insurance (if you companies we identify)

(after you lock in your interest rate) use companies we identify)

Owner’s title insurance (if you do not

Transfer taxes Required services that you can use companies we identify)

shop for (if you use companies

we identify) Initial deposit for your escrow account

Government recording charges Daily interest charges

Homeowner’s insurance





Using the In this GFE, we offered you this loan with a particular interest rate and estimated settlement charges. However:

tradeoff table • If you want to choose this same loan with lower settlement charges, then you will have a higher interest rate.

• If you want to choose this same loan with a lower interest rate, then you will have higher settlement charges.

If you would like to choose an available option, you must ask us for a new GFE.

Loan originators have the option to complete this table. Please ask for additional information if the table is not completed.



The same loan with lower The same loan with a

The loan in this GFE

settlement charges lower interest rate



Your initial loan amount $ $ $



Your initial interest rate 1 % % %



Your initial monthly amount owed $ $ $



Change in the monthly amount owed from No change You will pay $ You will pay $

this GFE more every month less every month



Change in the amount you will pay at No change Your settlement charges Your settlement charges

settlement with this interest rate will be reduced by will increase by

$ $

How much your total estimated settlement $ $ $

charges will be



For an adjustable rate loan, the comparisons above are for the initial interest rate before adjustments are made.

1









Using the Use this chart to compare GFEs from different loan originators. Fill in the information by using a different column for each GFE

you receive. By comparing loan offers, you can shop for the best loan.

shopping

chart This loan Loan 2 Loan 3 Loan 4



Loan originator name

Initial loan amount

Loan term

Initial interest rate

Initial monthly amount owed

Rate lock period

Can interest rate rise?

Can loan balance rise?

Can monthly amount owed rise?

Prepayment penalty?

Balloon payment?



Total Estimated Settlement Charges







If your loan Some lenders may sell your loan after settlement. Any fees lenders receive in the future cannot change the loan you receive

is sold in the or the charges you paid at settlement.



future

Good Faith Estimate (HUD-GFE) 3

SERVICING DISCLOSURE STATEMENT

Officer: A160009



Loan Number Date Transaction Key Officer









APPLICANT INFORMATION



Earl Test

64 Sanford Drive

Fredericksburg, VA 22406



LENDER. "Lender" means Virginia Partners Bank whose address is 410 William Street, Fredericksburg, Virginia

22401 , its successors and assigns, and will be referred to in this Statement as "we", "our" or "us."



APPLICANT. "Applicant" means each person who signs this Statement, and will be referred to as "you" or "your".



NOTICE TO FIRST LIEN MORTGAGE LOAN APPLICANTS: THE RIGHT TO COLLECT YOUR MORTGAGE LOAN

PAYMENTS MAY BE TRANSFERRED.



You are applying for a mortgage loan covered by the Real Estate Settlement Procedures Act (RESPA) (12 U.S.C.

2601 et seq.). RESPA gives you certain rights under Federal law. This statement describes whether the servicing for

this loan may be transferred to a different loan servicer. "Servicing" refers to collecting your principal, interest, and

escrow payments, if any, as well as sending any monthly or annual statements, tracking account balances, and

handling other aspects of your loan. You will be given advance notice before a transfer occurs.



SERVICING TRANSFER INFORMATION. The loan for which you have applied will be serviced at this financial

institution and we do not intend to sell, transfer, or assign the servicing of the loan.



_____________________________________________________________________________________________



ACKNOWLEDGMENT OF MORTGAGE LOAN APPLICANT



I have read this disclosure form, and understand its contents, as evidenced by my signature below. I understand that

this acknowledgment is a required part of the mortgage loan application.







__________________________________



Earl Test Date



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