HERA Law Update

Every bank is applying different twists to the new HERA law updates regarding the TIL (Truth-In-Lending) disclosure. The appraisal process is even more complicated now, not only do you have to wait to collect the fees, some banks are imposing a wait period to order the appraisal. You could be looking at close to a week before you can receive payment and/or order the appraisal. A few banks are requiring for an initial TIL to be disclosed and also a final TIL prior to closing. Some banks wait time on the initial TIL disclosure is 8 business days, with Saturday counting as one of those days. And once you receive a clear-to-close, they are imposing another 7 business wait for the final TIL disclosure. You must pick the date you would like to close and keep it, because any minor changes could result in a change to the APR, which would result in re-disclosure of the TIL documents and you could easily add another 7 business days to your closing date. If this sounds over-the-top and a pain, you are CORRECT! The government has gone from giving a loan to anyone with a pulse, to making extremely difficult for anyone to qualify and close in a timely manner. With all of these new laws and changes, you cannot realistically close in 30 days, and there will need to look at a 45 or 60 lock. What that does is, possibly increase your rate for the extend period to protect the rate. Now add on the nightmare problems HVCC (The appraisal law that is crippling the real estate industry), and you can see why when you combine all of these changes, it is becoming, nothing short of a nightmare to get adequate financing for good borrowers. And the government has the nerve to say they are trying to help people…WHAT A JOKE!! Ifyou are a realtor, please do not submit contracts with a 30 day settlement, you are taking a big risk. If you are a borrower, please be prepare to provide additional documents than before, and need to understand why rates can increase when they are locked for periods over 30 days.


DC Metro Area Mortgage Broker
Bethesda, MD Homes