To help you visualize how MDIA and HVCC will affect a typical closing see the slides below. I've included a few calendars to help illustrate various scenarios you may encounter, including email vs. mail delivery system, and how redisclosing the TIL affects the closing date.
1. Monday Tuesday Wednesday Thursday Friday Saturday Sunday
1
Buyer makes offer
2
Realtor gets Lender in
contact with Title Co. to
gather fees for initial TIL1
3 4
- Buyer & seller finalize
offer
- Loan is locked
- Initial TIL emailed for
immediate receipt
- Appraisal fee collected
and appraisal ordered
5 6 7
8 9 10 11
- Appraisal received
- Appraisal emailed to
buyer for immediate
receipt
(Day 1 appraisal review
wait)2
12
1st day loan can close per
HERA (7 day wait)
(Day 2 appraisal review
wait)2
13
(Day 3 appraisal review
wait)2
14
15
1st day loan can close per
HVCC (3 day appraisal
review wait)
16 17 18 19 20 21
22 23 24 25 26 27 28
29 30 1. Real Estate Agents should work quickly to determine Title Co. so that Lender may contact them ASAP for their fees
2. Per HVCC, a buyer must receive the appraisal for review 3 days before closing
Email Delivery System for TIL & Appraisal
This example only shows regulatory wait periods, and does not take into account lender turntimes.
Therefore, it is not necessarily a true picture of how long it will take to close a loan.
2. Email Delivery System for TIL & Appraisal
(with TIL redisclosure delay)
This example only shows regulatory wait periods, and does not take into account lender turntimes.
Therefore, it is not necessarily a true picture of how long it will take to close a loan.
Monday Tuesday Wednesday Thursday Friday Saturday Sunday
1
Buyer makes offer
2
Realtor gets Lender in
contact with Title Co. to
gather fees for initial TIL1
3 4
- Buyer & seller finalize
offer
- Loan is locked
- Initial TIL emailed for
immediate receipt
- Appraisal fee collected
and appraisal ordered
5 6 7
8 9 10 11
-Appraisal received and
value is below sales price
- Appraisal emailed to
buyer for immediate
receipt
(Day 1 appraisal review
wait)2
12
1st day loan can close per
HERA (7 day wait)
(Day 2 appraisal review
wait)2
13
(Day 3 appraisal review
wait)2
14
15
1st day loan can close per
HVCC (3 day appraisal
review wait)
-Sales price renegotiated
and loan amount lowered
- Redisclose TIL via email
for immediate receipt 3
(Day 1 TIL review wait)2
16
(Day 2 TIL review wait)2
17
(Day 3 TIL review wait)2
18
1st day loan can close per
HERA’s APR redisclosure
period (3 day review wait)
19 20 21
22 23 24 25 26 27 28
29 30 1. Real Estate Agents should work quickly to determine Title Co. so that Lender may contact them ASAP for their fees
2. Per HVCC and HERA, a buyer must receive the appraisal and redisclosed TIL for review 3 days before closing
3. Change in loan amount triggered TIL redisclosure. Other changes that will trigger a TIL redisclosure, and delay closing are:
1. Change in interest rate
3. Mail Delivery System for TIL & Appraisal
This example only shows regulatory wait periods, and does not take into account lender turntimes.
Therefore, it is not necessarily a true picture of how long it will take to close a loan.
Monday Tuesday Wednesday Thursday Friday Saturday Sunday
1
Buyer makes offer
2
Realtor gets Lender in
contact with Title Co. to
gather fees for initial TIL 1
3 4
- Buyer & seller finalize
offer
- Loan is locked
- Loan application &
disclosures emailed to
buyer
5 6 7
8
-Buyer returns loan
application & disclosures
- Lender submits file to
investor
- Investor mails initial TIL
to buyer
9
(Day 1 TIL mail wait) 2
10
(Day 2 TIL mail wait) 2
11
(Day 3 TIL mail wait) 2
12
Appraisal fees collected &
appraisal ordered
13 14
15 16
1st day loan can close per
HERA (7 day wait)
17 18 19
Appraisal received &
mailed to buyer
20
(Day 1 appraisal mail
wait)2
21
22
(Day 2 appraisal mail
wait)2
23
(Day 3 appraisal mail
wait)2
(Day 1 appraisal review
wait)3
24
(Day 2 appraisal review
wait)3
25
(Day 3 appraisal review
wait)3
26
1st day loan can close per
HVCC (3 day appraisal
review wait)
27 28
29 30 1. Real Estate Agents should work quickly to determine Title Co. so that Lender may contact them ASAP for their fees
2. It is assumed the buyer receives TIL and/or appraisal 3 days after mailing
3. Per HVCC, a buyer must receive the appraisal for review 3 days before closing
4. Mail Delivery System for TIL & Appraisal
(with TIL redisclosure delay)
This example only shows regulatory wait periods, and does not take into account lender turntimes.
Therefore, it is not necessarily a true picture of how long it will take to close a loan.
Monday Tuesday Wednesday Thursday Friday Saturday Sunday
1
Buyer makes offer
2
Realtor gets Lender in
contact with Title Co. to
gather fees for initial TIL 1
3 4
- Buyer & seller finalize
offer
- Loan is locked
- Loan application &
disclosures emailed to
buyer
5 6 7
8
-Buyer returns loan
application & disclosures
- Lender submits file to
investor
- Investor mails initial TIL
to buyer
9
(Day 1 TIL mail wait) 2
10
(Day 2 TIL mail wait) 2
11
(Day 3 TIL mail wait) 2
12
Appraisal fees collected &
appraisal ordered
13 14
15 16
1st day loan can close per
HERA (7 day wait)
17 18 19
-Appraisal received and
value is below sales price
- Appraisal mailed to buyer
20
(Day 1 appraisal mail
wait)2
21
22
(Day 2 appraisal mail
wait)2
23
(Day 3 appraisal mail
wait)2
(Day 1 appraisal review
wait) 3
-Sales price renegotiated
and loan amount lowered
- Redisclose TIL via mail4
24
(Day 2 appraisal review
wait) 3
(Day 1 TIL mail wait)2
25
(Day 3 appraisal review
wait) 3
(Day 2 TIL mail wait)2
26
1st day loan can close per
HVCC (3 day review wait)
(Day 3 TIL mail wait)2
(Day 1 TIL review wait) 3
27
(Day 2 TIL review wait)3
28
29
(Day 3 TIL review wait)3
30
1st day loan can close per
HERA’s APR redisclosure
period (3 day review wait)
1. Real Estate Agents should work quickly to determine Title Co. so that Lender may contact them ASAP for their fees
2. It is assumed the buyer receives TIL and/or appraisal 3 days after mailing
3. Per HVCC and HERA, a buyer must receive the appraisal and redisclosed TIL for review 3 days before closing
4. Change in loan amount triggered TIL redisclosure. Other changes that will trigger a TIL redisclosure, and delay closing are:
1. Change in interest rate
2. Change in mortgage product (30 yr vs. 15 yr)