Disclosure Tracking

2010 Disclosure Tracking Tool

The Disclosure Tracking tool provides disclosure timelines and tracking dates, the disclosure history, and the latest disclosure details. Use this tool to log GFE, REGZ-TIL, and other disclosures. Follow the timelines and tracking dates to stay compliant with Real Estate Settlement Procedures Act (RESPA) regulations that went into effect on January 1, 2010, as well as provisions to the Mortgage Disclosure Improvement Act (MDIA) that went into effect on July 30, 2009 and Consumer Financial Protection Bureau (CFPB) regulations effective January 2014.

This help topic describes the version of the Disclosure Tracking Tool used to record disclosure information related to the 2010 GFE and 2010 REGZ-TIL disclosures. Your Encompass administrator configures when your company switches by default from the 2010 to the 2015 forms. However, if you have not yet sent your initial disclosure to the borrower, you can switch between the 2010 and 2015 versions of the forms by clicking Forms on the Encompass menu bar, pointing to RESPA-TILA Form Version, and then clicking the 2010 or 2015 option. To view the help topic for the Disclosure Tracking Tool used to record disclosure information for the 2015 disclosure forms (RegZ - LE and RegZ - CD forms), refer to the 2015 Disclosure Tracking help topic.

To Open the Disclosure Tracking Tool:

  1. Open a loan and then click the Tools tab.
  2. Click Disclosure Tracking.

 

ClosedCompliance Timeline

The Compliance Timeline calculates important time periods and dates according to MDIA regulations. All fields, with the exception of the Estimated Closing Date, are Read Only and calculated automatically. For details about how each field is calculated, view the 2010 Disclosure Tracking Compliance Timeline and Tracking Calculations help topic.

  • GFE Application Date - The date the loan application is received by the loan originator. The Send Initial Disclosure alert is generated on this date based on the completion of required fields on the loan file.

    • Click the blue Lock icon to manually enter a date.

  • TIL Application Date - Date on which the creditor receives a written application (submission of a borrower’s financial information in anticipation of a credit decision). An application is received when it reaches the creditor. If it reaches the creditor through an intermediary agent or broker, the application is received when it reaches the creditor, not when it reaches the agent or broker. This application date is checked during the Encompass Compliance Service test for MDIA compliance.

  • Initial Disclosure Due Date - The date the GFE must be disclosed to the borrower. Disclosure must take place within three business days (according to Our Company Calendar) of the GFE Application Date. The GFE Application Date is considered day 1. Disclosure is required by the end of day 3.

     By default, the GFE Application Date is included in the Initial Disclosure Due date calculation (i.e., it is considered day 1). However Encompass administrators may use the Disclosure Tracking Settings tool to exclude the GFE Application Date from this calculation. Consult with your Encompass administrator to confirm if the GFE Application Date is included.

  • Earliest Fee Collection Date - Under RESPA regulations, lenders and mortgage brokers cannot collect any fees for an inspection or appraisal (or similar services), with the exception of a credit report fee, until the GFE and REGZ-TIL are received by the borrower and they have indicated an intention to proceed with the loan (field ID 3164). The Earliest Fee Collection Date is the later of the following dates: the date you determine that the borrower intends to continue with the loan (field ID 3197) or the date when the borrower received the initial REGZ-TIL or GFE. The received date is set as the date fax sent, date email opened, 3 days after mailed, or 1 day after sent by overnight delivery.

  • Earliest Closing Date - The earliest the loan can be closed. This date is 7 days (Sundays and legal holidays excluded) after the Initial TIL Sent Date and 3 days (Sundays and legal holidays excluded) after the Revised TIL Borrower Received Date.

  • Estimated Closing Date - Enter the estimated date the loan will close.

  • Disclosure Tracking Timezone - Indicates the time zone being used for the time and date calculations in the loan file. The time zone indicated here is based on the time zone indicated in field LE1.X9. The default value for this field is determined by the Closing Costs Expiration Time Zone setting (Encompass Settings > Loan Setup > Disclosure Tracking Settings > Compliance Timeline Calculation for RESPA-TILA.)

ClosedTIL Tracking

Use this section to track when the initial and revised REGZ-TIL is sent and received by the borrower. All fields are Read Only.

  • Initial TIL Sent Date - The date the first version of the REGZ-TIL is sent to the borrower.

  • Borrower Received Date - The date the first version of the REGZ-TIL is received by the borrower.

     This date varies based on the delivery method. Possible dates are the date the REGZ-TIL was sent via fax, the date the email containing the REGZ-TIL was opened, 3 days after it was mailed, or 1 day after it was sent by overnight delivery.

  • Revised TIL Provided Date - The date the revised REGZ-TIL is sent to the borrower.

  • Borrower Received Date - The date the revised REGZ-TIL is received by the borrower.

     This date varies based on the delivery method. Possible dates are the date the REGZ-TIL was sent via fax, the date the email containing the REGZ-TIL was opened, 3 days after it was mailed, or 1 day after it was sent by overnight delivery.

ClosedGFE Tracking

Use this section to track when the initial and revised GFE is sent and received by the borrower. All fields are Read Only.

  • Initial GFE Sent Date - The date the first version of the GFE is sent to the borrower.

  • Borrower Received Date - The date the first version of the GFE is received by the borrower.

    This date varies based on the delivery method. Possible dates are the date the GFE was sent via fax, the date the email containing the GFE was opened, 3 days after it was mailed, or 1 day after it was sent by overnight delivery.

  • Revised GFE Provided Date - The date the revised GFE is sent to the borrower.

  • Borrower Received Date -The date the revised GFE is received by the borrower.

     This date varies based on the delivery method. Possible dates are the date the GFE was sent via fax, the date the email containing the GFE was opened, 3 days after it was mailed, or 1 day after it was sent by overnight delivery.

ClosedOther Tracking

Use this section to type or select the date on which the Affiliated Business Disclosure, CHARM Booklet, HUD Special Booklet, and HELOC Brochure are sent to the borrower.

  • Affiliated Business Disclosure Provided - The date an Affiliated Business Arrangement Disclosure is provided to the borrower.

  • CHARM Booklet Provided - The date the licensee provided the Consumer Handbook on Adjustable Rate Mortgages (CHARM) or a suitable substitute at the time of application.

  • HUD Special Booklet Provided - The date that HUD's Special Information Booklet is sent to the borrower.

  • HELOC Brochure Provided - The date the Special Brochure for Open-Ended Credit Plans is sent to the borrower.

  • 1st Appraisal Provided - The date the appraisal is sent to the borrower.

  • Subsequent Appraisal Provided - The date the second appraisal is sent to the borrower.

  • AVM Provided - The date the automated valuation model (AVM) report is provided to the borrower. AVMs usually include the tax assessor's value and all pertinent information on the property in question, such as its sales history, and an analysis of the sales of like-kind properties.

  • Home Counseling Disclosure Provided - The date home ownership counseling information is provided to the borrower.

ClosedDisclosure History

An entry can be added to the Disclosure History using three different methods. Entries can be added automatically, manually, or by clicking Yes when a Disclosure Tracking prompt displays, asking if you want to create a Disclosure History entry.

ClosedAutomatic Disclosure History Entry

A Disclosure History entry is automatically added when:

ClosedTo Manually Add a Disclosure History Entry

  1. Click the New icon.

  2. When prompted, select the documents included in the disclosure (if applicable).

  3. Click Yes.

ClosedTo Add a Disclosure History Entry Using a Disclosure Tracking Prompt

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.

 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.

  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.

 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.

ClosedTo Delete a Disclosure History Entry

Once 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, nor the TIL Tracking and GFE Tracking sections.

  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, or TIL and GFE Tracking sections.

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

ClosedDisclosure Details

To view the details for a specific disclosure, double-click to open the associated Disclosure History entry.

ClosedDetails Tab

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

  • The Disclosure Information section provides the disclosure or disclosure package's Sent Date, by whom it was sent, the sending method, and the date the borrower received the disclosure or disclosure package.

  • Click the blue lock icon to manually enter a Sent Date date.

  • To change the Method the disclosure or disclosure package was sent, select an option from the dropdown list.

  • Additional comments can be manually entered in the Comments area. This area may also be auto-populated with comments from the 2010 GFE.

  • The Loan Snapshot section provides the key loan fields that were disclosed to the borrower. If the GFE was sent, click the GFE Snapshot button to view a Read Only copy of the disclosed GFE.

  • The Documents Sent 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.

ClosedeDisclosure Tracking Tab

 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.

  • The read-only fields in the Status section are auto-populated with the date on which the borrower and co-borrower (if applicable) accesses, accepts, rejects, or electronically signs the eDisclosure package.

  • 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 and by whom the package was ordered.

  • 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.

See Also: 

Disclosure Tracking Settings

Disclosure Tracking Compliance Timeline and Tracking Calculations

Alerts Overview

Alerts Setup

eDisclosure Fulfillment Service