The closing fees listed within the TRID Closing Fee page located in settings is confusing and over-complicated. I am suggesting a rework of this page to simplify and more clearly state what is included in the APR calculation.
1. There are more costs listed than we need.
-The page was based off the Closing Disclosure, but we deal more with the early estimates as stated on the Loan Estimate.
- We include the section of the Closing Disclosure each fee is included in, even though we do not provide the disclosure itself.
- I would like to suggest removing those fees that will never impact the APR (Mortgage Insurance, Homeowners Insurance, Property Taxes, etc.)
2. Usability is lacking due to the layout and available options.
- We require the user to chose their payment option: Borrower-Paid At Closing, Borrower-Paid Before Closing, Seller-Paid At Closing, Seller-Paid Before Closing, and Paid by Others.
- The section where the fee is to be located on the Closing Disclosure is unnecessary. I suggest this option be removed.
3. The lack in usability impacts the perceived accuracy of the APR calculation.
- Only the Borrower-Paid At Closing is included in the APR calculation. I suggest this be more clear with one of 2 options:
- Option 1: Add a check-box to each fee (similar to the QM/HOEPA check box) that would allow the customer to choose which fees are included in their APR.
- Option 2: Change the payment drop down into a "Used in APR?" drop down, with options that include "Included in APR" and "Not Included in APR". These would be the only 2 options, removing the confusion of the dropdown.
These updates would give the customer more clarification into what is going into their APR calculation and would remove any liability for us making assumptions for how all lenders are interpreting regulation.
|Revenue or Retention?||Other|
|Impact to Existing Customers||Multiple|
|Customer ID(s)||Those entering Fees into the TRID Closing Fee Screen|
|Business Value||1 - Important to a few or none, little or no impact on brand, little or no competitive advantage|
|Urgency||1 - Not time constrained|