TRID 2.0 Tip - Property Value

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kgoulart@ibat.org
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TRID 2.0 Tip - Property Value

Property Value – Revisions to 12 CFR Pt. 1026, Supp. I, Paragraphs 37(a)(7) – 1 & 38(a)(3)(vii) – 1 provide further guidance as to what should be disclosed for “Estimated Value” and “Est. Property Value” on the LE and CD, respectively (which replace the “Sale Price” disclosures on the first page of both documents for transactions which do not involve a seller). They permit creditors the option to disclose the estimated value of the property after construction work is completed. To wit:

 

“[For the LE.] In transactions where there is no seller, such as in a refinancing, § 1026.37(a)(7)(ii) requires the creditor to disclose the estimated value of the property . . . based on the best information reasonably available to the creditor at the time the disclosure is provided to the consumer, which may include, at the creditor’s option, the estimated value of the improvements to be made on the property in transactions involving construction. . . .” (Ibid. Paragraph 37[a][7] – 1)

 

“[For the CD.] . . . For transactions involving construction where there is no seller, the creditor must disclose the value of the property that is used to determine the approval of the credit transaction, including improvements to be made on the property if those improvements are used in determining the approval of the credit transaction.” (Ibid. Paragraph 38[a][3][vii] – 1)

 

Kelly Goulart  - Regulatory Compliance Manager

Direct = 512-275-2231  Email = kgoulart@ibat.org