Written by Richard Triplett, CMB*

In keeping with the previous articles written on general RESPA reform, Page 1 and Page 2 of the revised GFE, this article will cover the last page (Page 3) of the revised GFE. The page itself is titled "Instructions". Despite the fact that the page is identified as an instruction page to the applicant, this page in conjunction with "Important Dates" on Page 1, and the tolerances regarding charges on Page 2, has the potential to offer various levels of confusion to the typical applicant, in any transaction but particularly in a wholesale transaction. I will discuss what I perceive as areas that still tend to offer confusion with some additional comments below regarding what I call the "Wholesale Triangle". There remain multiple areas of the new mandated GFE in which clarification will be necessary to alleviate some of the possible liability to mortgage brokers and lenders alike. I will start with covering the content of the page and then delve into those confusing areas of the new disclosure.

This month DSI posts updates to the loan program of GMAC Bank to its Compliance page. Find out the description of each investor's loan program, which promissory notes, prepayment riders and addenda are used, and what the rate caps and interest-only periods are for variable rate loans by visiting our Investor Updates page.

In order to keep DocMagic software users better apprised of document changes and additions as they occur, DSI posts listings of all newly created and revised documents. Here is the list of forms created or modified in March, 2009.