Nov 20

A Realtor’s Guide: The New FAR/BAR Contract and Settlement Statement Changes Due to the New CFPB and TRID Requirements

A REALTOR’S GUIDE:
THE NEW FAR/BAR CONTRACT AND SETTLEMENT STATEMENT CHANGES
DUE TO THE NEW CFPB AND TRID REQUIREMENTS
(WITH CLARIFICATIONS TO THE DODD-FRANK ACT)

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As you are well aware, the new Consumer Finance Protection Bureau (CFPB) has mandated a new closing disclosure called TRID (which stands for TILA RESPA Integrated Disclosure) which has caused the FAR/BAR Contract to be modified to reflect this new issue. These new mandates started October 3, 2015, and the lenders must start taking new loan applications using the new procedures on that date. Therefore, we should start seeing closings governed by these new requirements kick in around November to December.

As a quick summary, the goal of TRID is to combine the Truth-in-Lending Disclosure, the Good Faith Estimate, and the HUD-1 Settlement Statement required by TILA and RESPA into two disclosures – the Loan Estimate, which you Realtors® and we real estate attorneys will not have to deal with much, since it is issued prior to closing, and the Closing Disclosure, which replaces the HUD-1 for most closed-end consumer mortgages. However, remember the Closing Disclosure is a disclosure from the lender to the borrower only. We as closing agents and you, as Realtors®, will need to see a Settlement Statement that mirrors the real estate contract and reflects the contract’s obligations and terms. We are either going to have to create a separate ALTA Settlement Statement to accomplish this goal or prepare riders to the Closing Disclosure, depending upon which method is dictated by each mortgage lender.

The preceding changes are substantial, and they are not just a group of new forms – they are creating a new process that we all have to adhere to and know. The new process requires new timeframes, such as closing agents compiling most all of the costs and fees (for the survey, home inspection, title, associations, estoppels, real estate taxes, documentary stamp taxes, Realtor® commissions and fees, etc.) and providing them to the lender at least fifteen (15) days prior to the closing. The lender must then take this information and provide the Closing Disclosure to the borrower at least 3 days prior to closing. The lender will not start the Closing Disclosure until it receives all Borrower charges.

The 5 new basic CFPB events you should know about:

1) Loan Application Event: Date when all six bits of required information go to the lender (see Paragraph C.18. below) and which starts the lender’s clock.

2) Loan Estimate Event: Must be given by the lender within three (3) days of the Loan Application and seven (7) days prior to closing.

3) Notice to Proceed Event: Given by the Buyer/Borrower and allows lender to move the loan process forward and to spend Buyer/Borrower’s money.

4) Closing Disclosure Event: Must be given by the lender three (3) days prior to closing (7 days if by mail).

5) Amended Closing Disclosure Event: Any changing facts or circumstances that cause the interest rate to change more than 1/8%, the loan product to change, or a prepayment penalty to be added, all of which require the Closing Disclosure deadline to be re-met, thus restarting the time referenced in Point 4 above.

A. FAR/BAR Contract Changes. All of these new TRID requirements are what is causing the latest revisions to the FAR/BAR Contract, and it is our goal to provide you not only up-to-date summary of the changes to the Contract (a tracked, summary version of the changes is enclosed), but also provide you with tips and guidelines. The changes to the Contract are as follows:

1. Paragraph 5, Extension of Closing Date. 5.a. has been modified so that the Closing Date can be extended for a period up to ten (10) days due to the new CFPB mandate that the Closing Disclosure must be delivered by a certain number of days prior to the Closing Date when the borrower/buyer becomes obligated to close the loan or the real estate purchase. Therefore, in the event the CFPB requirements regarding delivery of the Closing Disclosure are not met, the Closing Date will be extended for the number of days necessary to meet the delivery requirements, not to exceed ten (10) days (remember the Contract uses calendar days). Previously, this paragraph provided up to a seven (7) day extension to accommodate the mortgage lender.

2. Paragraph 8, Financing, has been modified in the following manner:

8.a. This was the box that you check if the transaction was a “cash” transaction (not contingent upon financing). It has been modified to reflect that this provision no longer specifies that the buyer may obtain a loan. However, this does not prohibit the buyer from doing so. New language is added to clarify that a cash buyer who later chooses to finance a transaction will not get an extension to close if the CFPB Closing Disclosure delivery requirements are not met.

8.b. The default time for the Loan Commitment Date (the timeframe for the buyer to obtain a Loan Commitment, a defined term in the Contract’s Paragraph T) is changed to 45 days after the Effective Date from 30 days, due to the fact that the financing process will take longer once the new rules become effective.

8.b.ii. Language is added here to clarify that an extension under Paragraph 5 (which is the extension of the Closing Date) will not change the Closing Date when calculating 7 days prior to the Closing Date. This prevents a deposit which becomes non-refundable at one point to becoming refundable later if there is an extension of the Closing Date due to CFPB delivery requirements.

3. Paragraph 9, Closing Costs; Title Insurance; Survey; Home Warranty; Special Assessments, has been modified in the following manner:

9.c. Title Evidence and Insurance. The default timeframe is modified for delivery of evidence of title for transactions involving mortgages (does not affect timeframe for cash deals). In the event the blank space describing when evidence of title is to be delivered is not filled, the default has been modified to 15 days prior to the Closing Date if Paragraph 8.b., c., or d. is checked, rather than 5 days. This is due primarily to the fact that lenders need this information earlier in the closing process than was previously the custom. If Paragraph 8.a. is checked and buyer is to pay cash, the default of 5 days remains unchanged. Additionally, “Title Evidence Deadline” is now a defined term for the delivery deadline of the title commitment and survey.

The description of the title insurance premium rates has also been modified to reflect that the premium charges for the owner’s and lender’s title insurance policies will be calculated in accordance with Florida law, but may be reported differently on the Closing Disclosure. This is now due to the new CFPB requirement that, while the cost of title insurance premiums for the owner’s and lender’s policies do not change, the premiums must be allocated and calculated differently on the Closing Disclosure. We will correct these costs when we show the buyer’s and seller’s sides on a separate ALTA Settlement Statement or addendum.

9.d. Survey. The outside time for the buyer to have the property surveyed will be the Title Evidence Deadline as specified in Paragraph 9.c. Previously, the Contract provided that a buyer had 5 days prior to closing to obtain the survey. Now, if the blank is not filled in as to when title is to be delivered under Paragraph 9.c., and Paragraph 8.b., c., or d. is checked (transaction involving a mortgage), the default timeframe for a buyer to obtain a survey will be at least 15 days prior to closing (same as the Title Evidence Deadline). If Paragraph 8.a. is checked (cash deal) and the blank in Paragraph 9.c. for the Title Evidence Deadline is not filled in, then the default will remain as 5 days prior to closing to obtain a survey.

As a result of all of these changes, title commitments, surveys, estoppel letters, etc., will all have to be ordered a lot earlier than before.

4. Paragraph 12. Property Inspection and Repair (does not apply to “As Is” Contracts).

This paragraph has been modified to create a blank to fill in as to how many days after the Effective Date the buyer has to conduct inspections on the property. A default of 15 days after the Effective Date is provided unless filled in otherwise. The 5 days prior to closing has been removed. This matches Paragraph 12 of the “As Is” Contract. It is believed that this will work better than the language previously contained in the Contract (i.e. the earlier of the 15 days after the Effective Date or 5 days prior to closing), considering that the blank provides flexibility for either cash or finance transactions.

5. Standard G. Force Majeure. Language was removed from this Standard specifying that “any cause not reasonably within the control of the parties” could serve as a basis to extend the Contract’s closing date. The language has been removed to avoid the unintended consequence of delaying closings beyond the extension of the Closing Date in Paragraph 5, when the lender is not able to fund the transaction.

6. There have been a few changes to the riders, specifically, the following:

a) Rider C. Seller Financing. This rider addresses the Dodd-Frank Act’s restrictions on seller-financing and has been modified to include interest-only loans for the one-property exclusion under the Dodd-Frank Act. A blank has been provided to insert the term of the interest-only loan and a default of 60 months if the term is left blank. Additionally, the rider has been modified to now allow for balloon mortgages with a term of five years (60 months) or less.

b) Rider F. Appraisal Contingency. This contingency has been modified to reflect a default date of at least 10 days prior to closing for a written appraisal to insure that the appraisal will be completed prior to the delivery of the Closing Disclosure.

c) Rider H. Homeowner’s/Flood Insurance. This rider modifies the default in this contingency, so that the timeframe for terminating the Contract has been decreased by 5 days if insurance (homeowner’s or flood) is too expensive. Now, the rider specifies that the contingency will need to be satisfied by the earlier of 30 days after the Effective Date or 10 days (rather than 5 days) prior to closing. The purpose of the earlier 10-day timeframe again is for this information to be available for timely preparation of the Closing Disclosure.

B. New Closing Statement. Since the Closing Disclosure replaces the HUD-1 Settlement Statement and the Closing Disclosure is simply a disclosure to the Borrower only, we still need a separate Settlement Statement to reflect the debits and credits that are dictated by the terms of the Contract between the buyer and the seller. Therefore, there will be a new standard Settlement Statement promulgated by the American Land Title Association (ALTA). The need for the ALTA Settlement Statement with both the buyer’s and seller’s sides in addition to the Closing Disclosure resulted from the following factors: The Closing Disclosure creates in an inaccurate disclosure of title premiums in Florida and many other states because the CFPB requires a federal calculation which differs from Florida’s promulgated rates. (These changes need to be adjusted between buyer and seller in order to reflect the true cost that each party is obligated to pay.) Additionally, lenders may (and some will) take the position that the buyer’s Closing Disclosure is not to be shared with third parties such as real estate agents and the seller. This is actually a TRID requirement. The lenders may actually require that the Settlement Agent prepare a separate seller Closing Disclosure and not show the seller charges on the buyer’s Closing Disclosure. Sellers, buyers and real estate agents have a need to see the actual charges paid by both parties in order to insure compliance with the Contract and to get a complete picture of the transaction. In order to address these issues, ALTA has developed a standard Settlement Statement, an example of which is attached hereto. It appears we will still have to do credits from a seller to a buyer to adjust costs if the seller is paying for the title insurance or a portion thereof.

Please note that the Closing Disclosure applies only to closings involving institutional loans. There will be a separate closing statement for buyers and sellers, however, on most all transactions.

Please note that we will not be able to use the old HUD-1 Settlement Statement as it presents certain legal issues and data entry issues for our computer systems and software.

As you can see, the ALTA Settlement Statement is very different in appearance. However, the essence of the statement is very similar to the HUD-1 in that it itemizes all of the costs, comes up with bottom lines for both the buyer and seller and adheres to the Contract. The numbers are just simply rearranged in different blocks and different locations. This is a lot better than the Closing Disclosure’s alternative, which is an additional rider to the Closing Disclosure relating to the seller’s expenses, resulting in a very cumbersome and even more gargantuan Closing Disclosure, which will be even more confusing than ever.

C. Realtor® Suggestions/Guidelines. While the above reflects the new changes to the FAR/BAR Contracts, I would like to turn your attention to some practical tips, suggestions, and guidelines that we have compiled, and we believe are either dictated by the new TRID process and changes or will assist you and us to avoid problems under the new closing process:

1. Closing Date Timeframe. We now have to provide accurate information to the lender at least 15 days prior to the closing. As such, please be liberal in your closing dates and recognize that closing dates may not be moved up as easily or as quick as in the past. We are recommending that cash deals are scheduled 3 weeks out with a 15-day inspection period, and for financed deals, 45-60 days with a 15-day inspection period.

2. Inspection Period Timeframe. We recommend a 15-day inspection period because the municipal lien search, which uncovers open permits, code enforcement violations, unpaid utilities, etc., cannot be obtained quickly. If there is an issue with any permits, we must uncover those within the inspection period in order for the buyer to timely object or back out. A lot of the municipalities and counties are now charging for these searches and information and can take more than a few days to provide the information. We do not want to get into a situation where this information is provided after the end of the inspection period, and therefore place the buyer in a bad situation by having to purchase the property subject to said open permits, unpaid utilities, etc.

3. Upfront Cost Liability. Being that the lenders are requiring this information at least 2 weeks prior to the closing, we now have to order and obtain the surveys, title insurance commitment, association fees, seller lender payoffs, estoppels, etc. well in advance of the closing date and the financing contingency or inspection period deadlines. As you well know, some of these costs must be paid up front, such as the association estoppels, surveys, etc. The buyers and sellers will have to be educated that they will have to front these monies and these are costs, and they will have to absorb these costs should the closing not occur. Some of the associations are charging $200-$400 for the estoppel letters and/or applications, and we will need to order these sooner than we have done in the past. In the event there is a longer time to close, then we would have to order updates to get accurate information prior to the closing, resulting in more costs. Please recognize that this is information that we need to know and documents we have to obtain in order for the closing to occur. Please educate your buyers and sellers accordingly. It is not the closing agent’s job or duty to front these buyer costs as they are now becoming substantial.

4. Effective Date. Please be very dutiful in making sure, when your clients sign the Contract, that they also date the Contract, as the Effective Date is becoming very important, and if the Contract is not dated, then we do not know what the Effective Date is. Please be very careful with e-signatures as some e-signatures do not have dates. Again, please do not choose very short inspection periods, as there are a lot of items that will need to be completed such as the municipal lien search within the inspection period, and obtaining some of those items is outside of our control. Most all inspection periods start from the Effective Date. Remember the Effective Date is when the last person signs and the Contract and Addenda are delivered back to the first party to sign. Please do a confirmatory email on the Effective Date to be safe.

5. Title Evidence Deadline Extension. Please extend the Title Evidence Deadline to coincide with the financing contingency in the Paragraph 9 in order for the title and survey to be completed during the financing contingency period.

6. Timeframes. Please remember that the FAR/BAR Contracts count time in calendar days, and the CFPB’s TRID regulations count days in business days, but not Saturdays (in most cases).

7. CFPB Regulations Only Deal with Financing and Dodd-Frank. Please note that CFPB regulations apply only to certain mortgage-financed purchases or refinances by consumers and do not apply to cash transactions, commercial transactions, HELOCs, reverse mortgages, or purchases by, or loans to, corporations, limited liability companies, or partnerships.

Please also note that Dodd-Frank seller-financing restrictions apply only to residences in which borrower/buyer intends to live all or part of the time, and there is still seller-financing available for vacant land, commercial properties, rental property, and purchases by corporations, limited liability companies, or partnerships. The TRID regulations also do not apply to qualified seller-financing or loans by persons who are not considered “creditors,” because they make five or fewer mortgages per year. Additionally, recent changes made it clear that balloon and interest-only loans can be given for now.

8. Appraisal Issues. Issues involving inspections may arise if the walk-through reveals deficiencies with the property, appliances removed, damage to the property, etc. This may trigger a requirement that the appraisal be updated, which would trigger a delay in the closing due to a change in value. The updated appraisal must be delivered to the buyer 3 days prior to closing, which should not create an issue for the Closing Disclosure, but if a walk-through 2 days prior to closing reveals an issue that the appraiser must re-evaluate, then the closing may be delayed even if the Closing Disclosure remains unchanged. As such, you may want to consider 2 pre-settlement inspections or walk-throughs with the first being 7-10 days in advance of the closing, and the second being the date of the closing. However, you would have to create a contract addendum to accomplish this.

9. Back-to-Back Closings. Back-to-back closings are becoming more difficult and should you have a back-to-back closing, you may want to put an addendum on the second contract to reflect that any closing delays caused by TRID regulations regarding the first contract will automatically create day-for-day extensions of the closing for the second contract.

10. Closing Disclosure Preparation and Delivery. Most lenders will be preparing the Closing Disclosure. However, we are getting the word that some lenders are requiring the closing agent to prepare the Closing Disclosure. The Closing Disclosure must be delivered to the buyer at least 3 business days prior to the scheduled closing date (and does not include Saturdays). Most lenders will send the Closing Disclosure by first class mail or by email which requires an additional 3 business days under the mailbox rule. Only changes to the annual percentage rate, changes to the loan product, or the addition of a prepayment penalty would trigger a new Closing Disclosure and a 3-day delay of closing. However, other changes may trigger new discussion such as changes in valuation.

11. Submittal of Costs to Lenders. We now have to provide to the lender, at least 15 days prior to the closing, all costs to appear on the Closing Disclosure that the buyer will need to pay. In addition to loan and title charges, we need to provide your commissions, administrative and document fees, your license number, e-mail, phone number, and your broker’s Florida license number and address along with estoppel fees, association fees, real estate taxes, survey charges, inspection fees, etc. As I mentioned earlier, some of these items will have to be ordered well in advance. The buyers and sellers will have some additional exposure in case the closing does not occur (these costs will still have to be paid if closing does not happen). The Closing Disclosure can only be sent to the buyer and the closing agent is not allowed to send the Closing Disclosure to anyone else, including you as a Realtor®. We will need to prepare a separate ALTA Settlement Statement and a seller’s Closing Disclosure that reflects the Contract and this will be sent to the parties and the Realtors®.

12. Communication. Please communicate all changes to the Contract to lender and closing agent as soon as possible. Establish the best way to communicate with all parties as early as possible. Keep your buyers, sellers, other Realtors®, and closing agent informed as to the new process and any changes, and please educate them as to the new deadlines and requirements as set forth herein. Quickness in responses between your buyers, sellers, and us will be vital, and good communication is going to be key in moving closings forward and with success. We will have to work more closely than ever before.

13. Increase in Costs. Needless to say, with additional steps and work from the lender, real estate broker, mortgage broker, Realtor® and closing agent standpoints, it is a fair bet that closing costs will go up. As you can well imagine, the more time each party spends, the more costs each party will incur, all of which will be passed on to the consumer. That being said, the promulgated rates for title insurance, closing fees, and title examination costs have not been increased for years, and we will most likely see these and other costs being pushed upward in the near future. Real estate brokers and their agents may wish to consider whether their current commission rates and administrative fees are adequate.

14. Two Sets of Timeframes. Remember, there are two different sets of timeframes for obtaining title evidence and a survey, with the first being the cash deal timeframe and the second being the “contract contingent upon financing” timeframe. As discussed above, if the financing contingency box is checked, then the time period as it relates to obtaining the title evidence and survey is 15 days prior to the closing. If it is a cash deal, then it is 5 days prior to closing. Remember, however, that if it is a cash deal, but the buyers later choose to obtain financing, then the cash deal timeframe controls.

15. Municipal Lien Search Timeframes. The municipal lien search report has different components including real estate taxes and assessments, unpaid utility bills, and code enforcement/open permit issues. The municipal lien search is required because some municipalities and counties consider the nonpayment of utilities a lien on the property (whether legal or not) and therefore, we perform the search to determine if there are any past due amounts. As part of the overall package that most lien search providers prepare, they perform an additional search on permit issues. Although the Contract does reference permits, the permits are not part of the title insurance. Searching for code enforcement issues and open permits relate to the buyer’s due diligence. Of course, if any code enforcement lien is recorded, we will certainly consider it a title issue. Obtaining these municipal lien searches in a timely manner is becoming difficult, not only because cities and municipalities require money upfront in order to conduct a search in a lot of cases, but the cities and municipalities are not sending this information to us very quickly. Additionally, because we have to send the costs of any items discovered to the lender well ahead of time, we may have to do a second search to update the information prior to closing, as they are typically only good for 30 days. Please remember that any permit issues are part of the inspection period, during which, if there are issues found, the buyer will have to object within the inspection period. However, any past due amounts that are considered liens will have to be remedied by closing in order to clear the title.

16. Multiple Listing Service Issues. Since there are issues that are unresolved, you may want to leave the listing in the status of “Active with Contract” or “Taking Back-up Offers,” as you deem advisable.

17. Pre-Qualification Letters. Pre-qualification letters have become commonplace and are very useful for a seller to determine whether the seller wants to move forward with a particular buyer. The question is, do the new regulations and procedures of the CFPB preclude Lenders from issuing pre-qualification letters? Remember under the TRID rules, the Loan Estimate must be given within three days of the borrower supplying six pieces of specific information: name, income, social security number, property address, estimated value of the property, and loan amount, which are usually (but not always) provided (with a lot more financial information needed by the lender) at the time of completing a loan application. Additionally, other disclosures must be given within the three business days, including multi-disclosure notices, notices of the borrower’s ten-day deadline to advise of his or her intent to proceed with the lender, service provider disclosures, etc. The Loan Estimate is typically given soon after a Contract is signed and the loan application is submitted, so the Loan Estimate is not considered a pre-qualification letter. It will depend on each lender as to whether they will issue some type of pre-qualification letter, and lenders might be able to give this pre-qualification letter despite not having been provided all six pieces of the information that triggers the requirement to give a Loan Estimate. Also, remember that a borrower can have as many lenders to give Loan Estimates as they want, and then the borrower can choose the best loan program. However, remember that the Loan Estimates are most often provided when the Contract is signed by the borrower and not prior to signing.

18. Your Role. As you can see from the above, the process is becoming increasingly complicated. Your clients will most likely look to you to help guide them. Become familiar with all of the new forms and procedures because your clients will expect you to be knowledgeable about the new practices. However, please remember your role, and do not overstep your boundaries as to your expertise. Do not give any lending, legal, accounting, engineering, or other advice outside of your scope of expertise. It is your role to direct your clients to consult the appropriate professionals in the process. Do not create liability for yourself or your broker by going beyond your scope.

19. Ordering Products and Services. If the lender or closing agent orders certain services and/or products on behalf of the buyer that the buyer can shop for, then the charges for these services cannot increase by more than a ten percent (10%) cumulative tolerance from the charges shown on the Loan Estimate. If the charges exceed the ten percent tolerance, the lender must refund the excess to the consumer. Therefore, it is a risk for the lender to have the product or service ordered by the lender or the closing agent. As a result, we expect buyers will be required to order their own products and services that they have the ability to shop for, such as a survey, title insurance, etc., so as not to violate a tolerance for which the lender will be responsible. Note that, if the consumer has the ability to shop for services and selects a service provider from the lender’s written list, these products and services are still subject to the 10% tolerance. “Shop for” is a defined term in the Closing Disclosure and means that, if the consumer is not required to use a certain service provider and chooses a provider outside of the lender’s written list, then the lender is not responsible for any increase in the charges. For example, if the cost of a survey is disclosed on the Loan Estimate, and the final charge is significantly higher than the estimate, then the lender could potentially be responsible for the overage if the closing agent or the lender ordered it on behalf of the buyer. We expect this will cause a material change in the process, and that buyers will have to shop for and order these products themselves. You, as a Realtor®, can help them with that process. However, be aware that there is a risk if you are ordering these products and services on behalf of your buyers, if you do not obtain their consent for the costs or if you do not make it clear to the vendors that the buyers, not you, are responsible for payment. Lenders and closing agents can no longer steer business without significant risk due to the 10% tolerance.

20. New 2146 Form. There is a new Florida Department of Financial Services disclosure and certification form called the 2146 that must be signed at all closings (residential and commercial). If there is no loan then we will mark the top boxes as “not applicable”. A copy is attached.

21. Lender Approvals of Closing Agents/Title Agents. Please note that closing and title agents now have to undergo a rigorous approval process by each lender, and then apply and sign up with the lender’s service providers to handle the TRID requirements and submittals. Please note that this approval process is very exhaustive. For example, our firm has undergone, in the past year, an extensive best practices management procedural change (mostly for the good), to qualify us for approval by lenders. We anticipate that this process will become even more rigorous, as we will most likely have to undergo certain audits to maintain our approved closing agent status with the lenders. We, at Barnes Walker, have been very proactive regarding the new TRID requirements, and, very early in the process, we reached out to, and were approved by, most all lenders, in order to have the systems in place that are necessary for a seamless transition. This process started about 8 months ago, and we are very comfortable with where we are at this point as far as being able to well serve you, the Realtors®, along with your buyers, sellers, and lenders.

We do believe that, notwithstanding others’ opinions, the sun will rise tomorrow and that the process will settle, once we get into a new routine after the new procedures become better known, adjusted for any problems, and become customary. This will happen, and we do not anticipate closings to diminish because of the new procedures. We will all become accustomed to the process and make deals happen. However, we do think there may be a silver lining in that, after an initial learning curve, the new TRID requirements will cause closing agents and mortgage lenders to provide the new Closing Disclosure and ALTA Settlement Statement to you and your buyers more quickly than in the past, since the mortgage lenders must approve the Settlement Statement well in advance. It also may possibly make some would-be FSBO sellers hesitant to handle their deals themselves because of the CFPB’s new TRID complexities, and requirements.

If you have any questions regarding the CFPB, TRID, Closing Disclosure, or Dodd-Frank Act, please do not hesitate to call us at 741-8224 or e-mail us. As always, we will answer your questions at no charge. If you would like a copy of the article e-mailed to you, please request one from our Firm Administrator, Connie Hoff, at CHoff@BarnesWalker.com.

Important Note: The information contained in the preceding Barnes Walker Educational Series article is summary in nature and is sent for educational purposes only to you as a member of the Realtor® Association of Sarasota and Manatee, Inc., of which we are a proud affiliate member. This article should not be considered as legal advice for your or your client’s situation, if any, nor is it intended as specific or detailed advice, as we do not have any information specific to your or your client’s situation. Further, the preceding article is not intended to be an all-inclusive discussion of the CFPB, TRID, Closing Disclosure, or Dodd-Frank Act, but a guide to the same, and there may be other matters not described in the article that may impact your particular situation. Therefore, always seek legal advice regarding your own unique situation. Finally, this article is intended as a public service and is not a solicitation seeking legal employment of our firm by you or your clients.