QualityExcellence_Encompass Disclosure Environment Download PDF to read it at ease
Redisclose REGZ-TIL (APR Change) (Mortgage Disclosure
Improvement Act (MDIA))
In accordance with MDIA provisions, Redisclose REGZ-TIL alerts are generated
when there is a difference between the value in the Disclosed APR (Field ID 3121
on the REGZ-TIL and Closing REGZ forms) and the Current APR field (Field ID
799 on the REGZ-TIL and Closing REGZ forms) greater than .125% (for
conventional loans; for ARM loans this alert is generated when the difference
between the two APR values is greater than .25%). The alert notifies loan team
members that the new APR should be disclosed to the borrower. The alert
displays on the Pipeline, the Alerts & Messages tab in the Log, and both REGZ
forms, as well as in a pop-up window when you save the loan.
- Your system administrator can set this alert to generate for ARM loans when
the difference between the two APR values is greater than .125%.
Closing Date Violation (MDIA)
To comply with MDIA provisions, a Closing Date Violation alert is generated when
the loan’s Estimated Closing Date (Field ID 763 on the Borrower Summary)
precedes the loan’s Earliest Closing Date (Field ID 3147 on the Disclosure
Tracking tool). The alert displays on the Pipeline and the Alerts & Messages tab
in the Log, as well as in a pop-up window when you save the loan.
Send Initial Disclosures (Real Estate Settlement Procedures Act
(2010 RESPA and 2015 RESPA-TILA)
- 2010 RESPA-TILA – According to RESPA, the loan originator must provide
the initial GFE and REGZ-TIL to the borrower within three days of receiving
the loan application. The Send Initial Disclosure alerts are generated when
all of the alert’s trigger fields have been populated. By default, these fields
include Borrower First Name (Field ID 4000), Subject Property Address
(Field ID 11), Loan Amount (Field ID 1109), and other fields used to complete the loan application. View the Send Initial Disclosures alert in the Alerts
settings tool for a full list of Field Triggers. These alerts display on the
Pipeline and the Alerts & Messages tab in the Log, as well as in a pop-up
window when you save the loan. Initial disclosures must be sent no later than
three business days after the alert has been generated. (Business days are
determined by the Our Company Calendar settings.)
- 2015 RESPA-TILA – This alert operates with the Loan Estimate (LE) the
same way in which the alert operates with the 2010 GFE form. According to
RESPA-TILA, the loan originator must provide the initial LE to the borrower
within three days of receiving the loan application. The Send Initial
Disclosures alerts are generated when all of the alert’s trigger fields have
been populated. By default, these fields are: Borrower First Name (field ID
4000), Borrower Last Name (field ID 4002), Borrower SSN (field ID 65), Total
Monthly Income (field ID 736), Subject Property Address (field IDs 11, 12, 14,
15), Subject Property Estimated Value (field ID 1821), and Loan Amount
(field ID 1109). These alerts display on the Pipeline and the Alerts &
Messages tab in the Log, as well as in a pop-up window when you save the
loan. Initial disclosures must be sent no later than three business days after
the alert has been generated. (Business days are determined by the Our
Company Calendar settings.) To clear this alert, the LE Sent Date (field ID
3152) must be populated. This field is populated automatically when the LE
is initially disclosed.
- Send Initial Disclosures Alert for Settlement Service Providers List – In
addition to the triggers for the 2015 RESPA-TILA alert discussed above, the
Send Initial Disclosures Alert may be triggered if the Loan Estimate and the
Settlement Services Provider List (SSPL) are required to be disclosed. The
alert is cleared when the SSPL Sent Date (field ID 4014) is populated. This
field is automatically populated when the SSPL is disclosed and a tracking
entry is included in the Disclosure Tracking tool’s Disclosure History table.
eSign Consent Not Yet Received (2015 RESPA-TILA)
This alert is intended to notify you when you have not yet received consent to
receive electronic disclosures from all applicable parties. This helps ensure you
receive eSigning consent before sending the disclosures electronically. View the
eSign consent status by clicking the Lookup icon (magnifying glass) for the eSign
Consent field on the Disclosure Tracking Tool.
These alerts display on the Pipeline and the Alerts & Messages tab in the Log, as
well as in a pop-up window when you save the loan. If the eSign Consent Status
for any borrower / co-borrower on the loan is not indicated as Accepted this alert
is triggered. This alert is triggered at the same time as the Send Initial Disclosures
alert. To clear the alert, the eSign Consent Status must be set to Accepted for all
borrowers and co-borrowers on the loan.
GFE Expires (2010 RESPA)
RESPA states that if a borrower does not express intent to continue with an
application within 10 days of receiving the GFE, the loan originator is no longer
bound by the GFE. The GFE Expires alert notifies you that the GFE Expiration
Date (Field ID 3140 on the 2010 GFE) is near and the loan’s rate has not been
locked. The days before the expiration date value set up in the Alert Settings
determines exactly when the alert displays. The GFE Expiration Date must be a
minimum of 10 days from the Initial GFE Sent Date (Field ID 3148 on the
Disclosure Tracking tool. (Days are determined by the Our Company Calendar
settings.) The alert displays in the Pipeline, the Alerts & Messages tab in the Log,
and the 2010 GFE (the top of the page displays in red), as well as in a pop-up
window when you save the loan.
Loan Estimate Expires (2015 RESPA-TILA)
The Loan Estimate Expires alert notifies you that the Closing Cost Estimate
Expiration Date (field ID LE1.X28 on the LE Page 1) is near and the Intent to
Proceed check box (field ID 3164) has not been selected on the Loan Estimate
Page 1. The days before the expiration date value set up in the Alerts settings
determines exactly when the alert displays. The LE’s expiration date must be a
minimum of 10 days from the LE Sent Date (Field ID 3152 on the Disclosure
Tracking tool). When the alert is generated, the Encompass user receives an alert
with the following message:
The Loan Estimate has expired because the Intent to Proceed was not received
within 10 business days from the LE Issued Date.
These alerts display on the Pipeline and the Alerts & Messages tab in the Log, as
well as in a pop-up window when you save the loan. Clear the alert by selecting
the Intent to Proceed check box on the Loan Estimate Page 1.
Redisclose GFE (Rate Lock) (2010 RESPA)
Under RESPA regulations, if a rate lock changes after the initial GFE is provided,
a revised GFE must be sent to the borrower within three days of the changes.
These Redisclose GFE alerts are generated when the Rate Locked Date (Field
ID 761) is later than the Last Sent Date (Field ID 3137) on the 2010 GFE. In other
words, the rate was locked after the 2010 GFE was initially disclosed. The alert
displays on the Pipeline, Log, and 2010 GFE (the top of the page displays in
red), as well as in a pop-up window when you save the loan. (Days are
determined by the U.S. Postal Calendar settings.)
Redisclose GFE (Changed Circumstances) (2010 RESPA)
Under RESPA regulations, if circumstances have changed since the initial
GFE was provided, a revised GFE must be sent to the borrower within three days
of the changes. These Redisclose GFE alerts are generated when the Changed
Circumstance check box (Field ID 3168) is selected on the 2010 GFE. The
Changes Received Date field (Field ID 3165 on the 2010 GFE) is populated with
the current date. The alert displays on the Pipeline, the Alerts & Messages tab in the Log, and 2010 GFE (the top of the page displays in red), as well as in a popup
window when you save the loan. (Days are determined by the U.S. Postal
Calendar settings.)
Redisclose Loan Estimate (Changed Circumstance)
(2015 RESPA-TILA)
Under RESPA-TILA regulations, if circumstances have changed since the initial
Loan Estimate was provided, a revised Loan Estimate must be sent to the
borrower no more than three business days after the changed circumstance is
received. The alert is triggered when the Changed Circumstance check box (field
ID 3168) on the Loan Estimate Page 1 is selected and the current date is
populated to the Changes Received Date (field ID 3165) on the Loan Estimate
Page 1. By default, the alert is triggered three days before the Redisclose Due
Date (field ID 3167).The alert displays on the Pipeline, the Alerts & Messages tab
in the Log, and in a pop-up window when you save the loan. (Business days are
determined the Our Company Calendar settings.)
HUD-1 Tolerance Violated (2010 RESPA)
To comply with RESPA tolerance regulations, these alerts are generated when
there is a discrepancy between any of the GFE and HUD-1 values in the Charges
that Cannot Increase section of the 2010 HUD-1 Page 3 form OR when the total
of the Increase between GFE and HUD-1 Charges (Field ID NEWHUD.X315) on
the 2010 HUD-1 Page 3 form is more than 10%. The alerts display on the Pipeline,
the Alerts & Messages tab in the Log, and at the top of the 2010 HUD-1 Page 3
page (the top of the page displays in red).
Ability-to-Repay Loan Type Not Determined (ATR/QM)
In accordance with the rule issued by the CFPB effective for applications on or
after January 10, 2014 that prohibits lenders from making a loan without first
considering and verifying a consumer’s ability to repay the loan and establishes
certain protections for creditors who make a “qualified mortgage”, this alert is
triggered when the Ability-to-Repay Loan Type (field ID QM.X23) has not been
indicated on the ATR/QM Management form. (By default, this alert is triggered at
the completion of the Approved milestone.) The alerts display on the Pipeline and
on the Alerts & Messages tab in the Log.
Qualified Mortgage Type Not Determined (ATR/QM)
In accordance with the rule issued by the CFPB taking effective for applications
on or after January 10, 2014 that prohibits lenders from making a loan without first
considering and verifying a consumer’s ability to repay the loan and establishes
certain protections for creditors who make a “qualified mortgage”, this alert is
triggered when the Qualified Mortgage Loan Type (field ID QM.X24) has not been
indicated on the ATR/QM Management form. (By default, this alert is triggered at
the completion of the Approved milestone.) The alerts display on the Pipeline and
on the Alerts & Messages tab in the Log.
QM Safe Harbor Eligibility Not Determined (ATR/QM)
In accordance with the rule issued by the CFPB effective for applications on or
after January 10, 2014 that prohibits lenders from making a loan without first
considering and verifying a consumer’s ability to repay the loan and establishes
certain protections for creditors who make a “qualified mortgage”, this alert is
triggered when the Is Loan Eligible for Safe Harbor? field (field ID QM.X25) has
not been populated on the ATR/QM Management form. (By default, this alert is
triggered at the completion of the Approved milestone.) The alerts display on the
Pipeline and on the Alerts & Messages tab in the Log.
Residual Income Assessment Recommended (ATR/QM)
In accordance with the rule issued by the CFPB effective for applications on or
after January 10, 2014 that prohibits lenders from making a loan without first
considering and verifying a consumer’s ability to repay the loan and establishes
certain protections for creditors who make a “qualified mortgage”, this alert is
triggered when the Ability-to-Repay Loan Type (field ID QM.X23) is Qualified
Mortgage, but it is not eligible for Safe Harbor (field ID QM.X23) OR the Ability-to-
Repay Loan Type is General ATR. This alert recommends a residual income
assessment. As the CFPB has not issued official guidelines or requirements for
residual income, this alert is a recommendation only and does need to be
addressed or cleared in order for the loan to qualify as a qualified mortgage. (By
default, this alert is triggered at the completion of the Approved milestone.) The
alerts display on the Pipeline and on the Alerts & Messages tab in the Log.
General QM DTI Exceeded (ATR/QM)
In accordance with the rule issued by the CFPB effective for applications on or
after January 10, 2014 that prohibits lenders from making a loan without first
considering and verifying a consumer’s ability to repay the loan and establishes
certain protections for creditors who make a “qualified mortgage”, this alert is
triggered when the loan’s Debt-to-Income (DTI) ratio (field ID QM.X119) exceeds
the limit for a General Qualified Mortgage. CFPB states DTI must be less than or
equal to 43% to meet General QM standard. The alerts display on the Pipeline
and on the Alerts & Messages tab in the Log.
General QM Loan Feature Violation (ATR/QM)
In accordance with the rule issued by the CFPB effective for applications on or
after January 10, 2014 that prohibits lenders from making a loan without first
considering and verifying a consumer’s ability to repay the loan and establishes
certain protections for creditors who make a “qualified mortgage”, this alert is
triggered when loan repayment data does not meet the standards for a General
Qualified Mortgage. The data entered in the Interest Only (field ID 2982),
Prepayment Penalty Period (field ID RE88395.X316), Prepayment Penalty (field
ID QM.X112), and The result of Points & Fees Test does not exceed the threshold
for Qualified Mortgages (field ID (QM.X124) fields on the ATR/QM Management
form’s Qualification tab and the Even if you make pmts on time, can your loan balance rise (field ID NEWHUD.X6) and Does your loan have a balloon payment
(field ID 1659) fields on the Loan Estimate Page 1 can trigger this alert. The alerts
display on the Pipeline and on the Alerts & Messages tab in the Log.
Ability-to-Repay Exemption Reason Not Determined (ATR/QM)
In accordance with the rule issued by the CFPB effective for applications on or
after January 10, 2014 that prohibits lenders from making a loan without first
considering and verifying a consumer’s ability to repay the loan and establishes
certain protections for creditors who make a “qualified mortgage”, this alert is
triggered when an ATR/QM Exemption Eligibility option has not been indicated at
the bottom of the ATR/QM Management form’s ATR/QM Eligibility tab. The alerts
display on the Pipeline and on the Alerts & Messages tab in the Log.
AUS Data Discrepancy (ATR/QM)
In accordance with the rule issued by the CFPB effective for applications on or
after January 10, 2014 that prohibits lenders from making a loan without first
considering and verifying a consumer’s ability to repay the loan and establishes
certain protections for creditors who make a “qualified mortgage”, these alerts are
generated when the information in the loan file does not match the last set of
values used by an Automated Underwriting System (AUS) to make an
underwriting decision. The alerts display on the Pipeline and on the Alerts &
Messages tab in the Log.
Redisclose Closing Disclosure (Changed Circumstance) (2015
RESPA-TILA)
Under RESPA-TILA regulations, if circumstances have changed since the initial
Closing Disclosure was provided, a revised Closing Disclosure must be sent to the
borrower. The revised Closing Disclosure must be sent within three days of the
changes. These Redisclose Closing Disclosure alerts are generated under the
following conditions: when the CD Changed Circumstance check box (field ID
CD1.X61) is selected, the Changes Received Date field (field ID CD1.X62) is
populated (which occurs automatically when the Changed Circumstance check
box is selected), and Change in Settlement Charges (field ID CD1.X55), Changed
Circumstance – Eligibility (field ID CD1.X68), Revisions requested by the
Consumer (field ID CD1.X66), Interest Rate dependent charges (Rate Lock) (field
ID CD1.X67), Tolerance Cure (field ID CD1.X57), Clerical Error Correction (field
ID CD1.X58), or Other (field ID CD1.X59) is then selected as the reason for the
changed circumstance. The alert displays on the Pipeline, the Alerts & Messages
tab in the Log, and in a pop-up window when you save the loan. (Business days
are determined by the Our Company Calendar settings.)
Redisclose Closing Disclosure (APR, Product, Prepay)
(2015 RESPA-TILA)
This alert will be generated when a prepayment penalty is added, the loan product
is changed, or the current APR differs from the Disclosed APR by more than
0.125% (0.25% for irregular loans) and the Closing Disclosure (CD) may need to
be redisclosed as a result. The trigger fields are:
- Trans Details Disclosed APR (field ID 3121) – Alert is triggered when the
Current APR (field ID 799) differs from the Disclosed APR (field ID 3121) by
more than 0.125% (0.25% for irregular loans) or custom percentage
- Product Description (LE1.X5) – Alert is triggered when the current Loan
Product (LE1.X5) on the CD Page 1 is different than the Loan Product
indicated on the last disclosure
- Prepayment Penalty (675) – Alert is triggered if Yes is currently indicated for
this field on the CD Page 1 and No was indicated in the last disclosure
- Last CD Sent Date (CD1.X47) – The date the CD was last disclosed.
These alerts display on the Pipeline and the Alerts & Messages tab in the Log, as
well as in a pop-up window when you save the loan. To clear this alert, redisclose
the CD or resolve the data in the trigger fields.
Good Faith Fee Variance Violated- This alert is generated when there is a
variance between the LE and 2015 Itemization in the Total Good Faith Amount
section (field ID FV.X345) of the Fee Variance Worksheet or when there is a
variance between the CD and 2015 Itemization in the Total Good Faith Amount
section (field ID FV.X347) on the worksheet. These alerts display on the Pipeline
and the Alerts & Messages tab in the Log, as well as in a pop-up window when
you save the loan.
- Click the alert icon or indicator to view the alert details, including each
applicable fee that was changed, and clear the alert. When viewing the alert
details, the following fee details are displayed (below the Trigger Fields
section) that provide the following information. Here you can enter fee
change details about each fee at a granular level:
- Applies To – At the top of this section, select LE or CD from the Applies To
drop-down list to indicate the form (LE or CD) where these fee change
details will be applied.
- Changes Received Date – Will auto-populate with today’s date and reflects
the same date used for this field on the LE Page 1 and CD Page 1
- Revised LE Due Date or Revised CD Due Date – In the Fee Details
section, you can indicate if the fee change was made on the LE Page 1 or
CD Page 1. Depending on the disclosure (as indicated by the selection in
the Applies To field), this field will refer to the LE due date or CD due date
accordingly. This is read-only field, calculated by the Encompass system.
- Description – Description of the Changed Circumstance (click the Lookup
icon (magnifying glass) to select the changed circumstance from the list).
- Comments – Comments related to the Changed Circumstance
- Reason – Select the reason for the change from the drop-down list. There
can only be one reason for each fee. This drop-down list provides the same
list of reasons that is provided on the LE Page 1 and CD Page 1. Some
reasons apply only to the LE, some apply only to the CD, and some apply
to both. If LE is selected for the Applies To field, only reasons that apply only
to the LE or LE and CD will be displayed in the list. If CD is selected for the
Applies To field, only reasons that apply only to the CD or the LE and CD
will be displayed in the list.
- These alerts display on the Pipeline and the Alerts & Messages tab in the
Log, as well as in a pop-up window when you save the loan. To clear this
alert, the amounts in the Variance between… fields (field ID FV.X345 and
FV.X347) can be updated to remove the variance amount from the Fee
Variance Worksheet or you can redisclose the LE or CD with a Change of
Circumstance selected that causes the Variance Worksheet LE or CD
Baseline to be updated, thereby removing the variance amount.
VA Discount Charge Violation
This alert triggers when the % Discount (field ID VARRRWS.X9) on the VA 26-
8923 Rate Reduction WS input form exceeds the 2% maximum allowed by the
VA.
Positive Aggregate Escrow Adjustment
Due to the calculations of single line analysis for biweekly escrows, certain
scenarios can result in the calculation of a positive aggregate escrow adjustment.
The Positive Aggregate Escrow Adjustment notifies the user if this scenario
occurs on the loan level. While the positive aggregate adjustment calculation is
technically correct, an investor or regulator might not approve purchasing a loan
with a positive aggregate adjustment. The alert informs the Encompass user that
a positive adjustment exists and suggests the user either move a portion of the
escrow items to prepaid (section 900 on the 2015 Itemization) or click the Lock
icon for the Aggregate Adjustment amount (field ID 558) to accept and retain the
positive number. The alert triggers when the Aggregate Adjustment amount (field
ID 558) is greater than 0. A link on the alert opens the 2015 Itemization input form
at the Aggregate Escrow field on line 1011. The alert clears when the Aggregate
Adjustment amount (field ID 558) is locked or when the field recalculates to be
equal to or less than 0.
Credit Limit Required
This alert is triggered when the Credit Limit (field ID FLxx31) is blank, the Account
Type (field ID FLxx08) is HELOC and the Will be Paid Off check box (field ID
FLxx18) is not selected.
Current and Proposed Lien position required if Resubordinated
This alert is triggered when the Current Lien Position (field ID FLxx28) or
Proposed Lien Position (field ID FLxx29) are blank, but the Resubordinated
Indicator check box (field ID FLxx26) is selected.
Current and Proposed Lien position required if Subject Property
This alert is triggered when the Current Lien Position (field ID FLxx28) or
Proposed Lien Position (field ID FLxx29) are blank, the Subject Property check
box (field ID FLxx26) is selected, and the Will be Paid Off check box (field ID
FLxx18) is not selected (regardless of resubordinated).
Custom Alert
The system administrator can create custom alerts that will be triggered under the
following circumstances:
- When a date is entered in a specific date field or on a specific day before or
after the date that is entered in the date field
- When a specific value is entered in a field
- When a value that is entered in a field falls between a specific value range
- When a combination of the previous circumstances occurs
These alerts display on the Pipeline and on the Alerts & Messages tab in the Log.
QualityExcellence_Encompass Disclosure Environment Download PDF to read it at ease
