TILA-RESPA Integrated Disclosures

Closing DisclosureFNC Enterprise Collateral Management

Origination, Servicing, Lending/Marketing and Capital Markets

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Focus• Most creditors have focused on:

• Generating a Loan Estimate and

• Generating a Closing Disclosure

• Today’s discussion

1. FNC’s TRID Tracker• Vendor credentialing, connectivity, communication, and collaboration

• Vendor fee tables

• Closing Disclosure presentment

• Secure myLoanPort app

• Secure web page

• Secure Interface into 3rd party mailing service

2. Connectivity to other systems

3. Demo

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Practical Challenges

Refinance Transactions

Creditors select all vendors from

approved list

• Approval, boarding and

engaging approved vendors

• Connecting and

communicating with approved

vendors

• Sending initial documents,

collaborating and approving of

final documents

Purchase Transactions

Consumer wants to use their title and

settlement agent; relationship issue

• Facility to immediately on-board

vendor

• Procedure to vet, authorize and

approve (or reject) vendor on a

limited basis; ability to test against a

prohibited or

exclusionary/inclusionary list

• Communicate, collaborate and send

final documents to ad-hoc approved

vendor

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Services We OfferVendor management

1. We solve 3rd party vendor management and oversight of your Settlement Agents

2. We enable lenders/creditors to vet, issue credentials, securely connect and communicate with your Settlement Agent vendors

3. We provide the software and service to do this for you• You set the criteria

• We will board your vendors including long-standing relationships and “one-off” vendors

• We will facilitate the ordering of background checks and other documentation according to your requirements

• We will monitor, update and maintain your vendors and their credentials

Closing Disclosure1. Collaboration via secure pipes

• Closing group at the lender/creditor

• Approved and credentialed Settlement Agents—on-going and ad hoc

2. Disclosures to and acknowledgement by the consumer

3. Audit logs and reports with retention

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Data and Documents to LoanPort

LOS

PROCESSOR

AND/OR

CLOSERSETTLEMENT

AGENTS

On-Going and

Ad HocCONSUMER

Feedback,

Disputes

Disclosure and

Acknowledgement

Uniform

Closing

Dataset

CollaborationData DisclosureVendor

Management

Vendor

information &

credentials

TRACKING TRACKING TRACKING TRACKING TRACKING

1. LOS is system of record

2. Settlement agents input coverage, services, data

and fees; creditor verifies, approves and issues

credentials;

3. All versions of Closing Disclosure issued by LOS

4. All disclosures via app, web page or mail service.

5. All audit logs, changes, and communications kept by

LoanPort and retained by FNC or sent to creditor.

Loan Estimate

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Solutions We Are Introducing

LoanPort• Secure portal for creditor’s employees,

agents (on-going and ad-hoc) and

consumers

• Secure communication, collaboration

and document exchange

myLoanPort• For consumers

• In the app store today

• Mobile method for acknowledgement

• Android/Google in GooglePlay store

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Collaboration on Documents and Data

Once a vendor is approved, how do we get documents and

data to them?• We assign a vendor credentials and enable them to securely connect to you, the

creditor

• We transmit documents and/or data to them through this secure connection

• They can communicate suggested changes in the documents and send back to

you (the creditor) for approval (and potential changes).

• We version each change, each document and provide an audit log of who

changed what and when

• We color code each change so you know if it is material and/or requires re-

disclosure

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Concerns• Fees to consumers in Loan Estimate

• Ability for vendors to provide current fees will be important

• For on-going vendors, we recommend a fee table that is vendor maintained

and creditor approved

• Many of you are planning to e-mail the Closing Disclosure to the

consumer if you obtain consent at application

• Document contains several items of personally identifiable information

• E-mail is typically sent “in the clear” and is typically not acknowledged

• Confirmed receipt/acknowledgement avoids additional 3 days of “mailbox rule”

so it is attractive

• We recommend secure e-mail, link/web page, secure app, or mail service

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Disclosure Time Table

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Consumer Disclosure and Acknowledgement

1. Web page disclosure and acknowledgement

2. App disclosure and acknowledgement• Apple/Safari/iOS

• Google/Android

3. Use of a mail service

• Key is getting the consumer to acknowledge disclosure and what to do (follow-up) if they do not acknowledge.• Additional notices

• Flags in the file

• Workflow discussion

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Brief Demo:

I. LoanPort

II. Solutions in the demo:

• Sending a Closing Disclosure form to an approved agent/vendor

• Collaboration between the settlement provider and the bank

• Tracking of changes and versioning between vendors and the

bank

• Approval of the changes by the bank

• Final disclosure

• Delivery to the applicant(s) and acknowledgement

• Data from the Closing Disclosure dataset

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Authentication of the Consumer• We use two factor authentication—think ATM withdrawals

• Something you know—your PIN

• Something you have—your ATM card

• For TRID

• Something you know—your e-mail address

• Something you have—your cell phone and/or iPad or Android equivalent

• Notices

• Prominent notice and permission for electronic disclosure

• Prominent notice and permission for electronic acknowledgement

• Prominent notice and permission to send text message

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Consumer’s Acknowledgement via Signature• Sign three different ways

• Draw your signature in the

drawing pad

• Upload your signature from a

file

• Sign via the app

• We turn your Apple or Android

device into a signing pad

• You sign with your finger and

upload

• Software captures signature

and time/date stamps

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What do you need to do to get this into production?

1. Get your account executive to give you a personalized demo—if you are new to FNC, please contact sales for a presentation.

2. Give us your list of criteria by state to be an approved settlement agent for your institution

• Do you want to populate database of vendors?

• Do you want FNC to populate database of vendors?

3. Get your account manager to work with your technical team to map to our LoanPort API for the Uniform Closing Disclosure to enable the two-way interface

4. Sign relevant documents

5. We will provide training on our solutions

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Who Needs What Technologies

Creditor

• Current browser—manufacturer

supported version of a major

browser such as Safari, Internet

Explorer, Chrome, Firefox

• Connectivity to the internet

• Ideal, two-way interface into the

creditor’s LOS supporting UCD

and ULDD

• Creditor account on LoanPort

Settlement Agent

• Current browser—

manufacturer supported

version of a major browser

such as Safari, Internet

Explorer, Chrome, Firefox

• Connectivity to the internet

• Settlement agent account

on LoanPort

• Valid credentials issued by

the creditor

• For Mobile phone app—iPhone 4S or higher with connectivity to the internet

• For web signing—manufacturer supported version of a major browser such as Safari, Internet Explorer, Chrome, Firefox

• For mailbox delivery—a valid USPS address

• Valid credentials issued by the creditor

Consumer

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Contact Information and Follow Up

Sales inquiriesLois Lovelady, Managing Director,

Sales and Marketing

llovelady@fncinc.com

662-236-2020 office

• To sign up for an in-house presentation:

• www.loanport.com

• You will see sign-up area on this page.

• Contact your account manager or salesperson at any time

Legal inquiriesNeil Olson, General Counsel

nolson@fncinc.com

662-236-2020 office

Technical inquiriesChristian Leask, Senior Product

Manager, Applications

cleask@fncinc.com

662-236-2020 office