Per the March Lending Announcement, there is a Loan Comparison Disclosure now required on VA Refinances that needs to be sent to the borrower within 3 days of application. We would like to provide a second option for branches in an effort to make the change easier.
Ellie Mae has been working on a new form in Encompass that will allow it to be filled out and sent with the initial disclosure package but it has not been released yet, hopefully sometime within the spring. In the meantime there is a second option you may utilize besides pulling the disclosure from Underwriting’s Shared Files and manually filling it out as instructed in the March Lending Announcement.
You may utilize the Net Tangible Benefit Tool within Encompass to fill in all previous loan information, reason(s) for the refinance, timeframe for recouping closing costs and other information we are required to provide per VA Circular 26-19-5. Instructions for providing the information has been provided by Ellie Mae. Please Note: you must manually fill in the “Borrower Received Reasonable, Tangible Net Benefit” box at the bottom as well since that will help fulfill conditions noted in the circular.
The Origination Compliance Department will review the file at initial disclosures to ensure one of the options has been completed.
An updated form for either option is also required in the closing package as new information from the previous loan comes to light and the current loan changes so we will also place a Pre-Closing Condition into the file for the form to be updated and provided in the closing package.
If you have any questions please contact Compliance@VanDykMortgage.com