Hard Money Lenders and TRID implementation?

Question

Hello- this question is for hard money lenders.  What challenges are you anticipating on Oct 3 this year when TRID is supposed to be implemented?

Based on my research, it looks like HMLs doing more than 5 loans a year are required to conform.

Any thoughts?

Thanks

( I lend HM in SLC, UT)

David Oldenburg · Answer

@Andy  Chu I lend on traditional loans, hard money loans and loan my own money.  TRID will be both a negative and positive for the investor world.  The previous exemptions for "bridge" or "temporary less than 12 month loans" is gone.  In other words, those loans are now included in TRID, unless they meet specific other exemptions.  There is the exemption previously mentioned for the private  lender doing 5 or fewer loans per year.  In addition, a "business purpose" loan is exempt.  I did a lot of research into the area of business purpose, and there are many different views on what this means.  A loan on an investment property, that will be flipped or rented, should fall into this category.  However, I believe all the proceeds need to be for business use.  I think a lot of the exemptions will become more clear, as TRID is implemented and time goes on.

The real advantage of TRID for the cash buyer, is the ability to close fast, without the additional delays and complexities that TRID will require.  Cash offers may appear very advantageous to a seller who needs or wants to sell quickly, or has fear of the buyer qualifying and being able to close 45-60 days down the road.  Good luck!

Andy Chu · Answer

TRID is required on not only Owner Occupant files but also second homes and Investment properties.

Charlie Fitzgerald · Answer

On owner occupied dwellings, you are correct.