Encompass 360 offers Changed Circumstances Setup tool to manage the list of changed circumstances users can select from when indicating a change in circumstance on the Loan (LE) Estimate Page 1, Closing Disclosure (CD) Page 1, and 2010 GFE input form. In this blog, we will explore on handling Change of Circumstance in Encompass 360.
Loan Estimate – Page 1
Disclosure Information
The Disclosure Information section displays information about the most recent Loan Estimate, the reason and changed circumstance for any redisclosure, and information about the most recently disclosed Loan Estimate that has not been excluded from the Disclosure Tracking timeline.
The Reason section enables a user to select the reason for redisclosing a Loan Estimate.
Fee Level Disclosures
The Fee Level Disclosures checkbox (field ID 4461) is provided above the list of changed circumstance reasons on the Loan Estimate (LE) Page 1 and Closing Disclosure (CD) Page 1 input forms. By default, this checkbox is NOT selected, which indicates that loans will be disclosed at a disclosure level. When this checkbox IS selected, fees must be redisclosed at the fee level (i.e., users must send revised disclosures when a fee is changed). You can document disclosure reasons with and without a changed circumstance when doing a fee level disclosure. Certain informational disclosure reasons on the LE Page 1 are available to select and enter details about, and they will be reflected in the Disclosure Tracking tool as applicable. This enables fee changes to continue to be documented at the fee level with the added benefit of permitting disclosure reasons to be identified at the disclosure level.
The following changed circumstance fields and reasons on the LE Page 1 are now always enabled so they can be selected to indicate a changed circumstance reason:
- Changed Circumstance (field ID 3168)
- Changes Received Date (if Changed Circumstance field is selected) (field ID 3165)
- Changed Circumstance text box and Lookup (magnifying glass) icon (if Changed Circumstance field is selected) (field ID 3169)
- Comments box (if Changed Circumstance field is selected) (field ID LE1.X86)
Reasons:
- Any Changed Circumstance that does not have a specific reason assigned to it.
- Other (field ID LE1.X84 and CD1.X59)
You can also open the Good Faith Fee Variance Violated alert and enter information in the alert that will then be populated to these fields as applicable.
It is important to consider that the disclosure level that is set with the Fee Level Disclosures checkbox is established once the initial disclosure (typically the LE) is sent. Once this initial disclosure has been sent, you cannot change the Fee Level Disclosures checkbox. Once you have disclosed at a fee level, you must continue to redisclose at a fee level for the remainder of the loan’s lifecycle (and vice versa if you have initially disclosed at a disclosure level). The Fee Level Disclosures checkbox will no longer be editable (i.e., it will be grayed out) once the loan is disclosed. For loans started in earlier versions of Encompass before this checkbox was available, the checkbox will not be selected.
Indicate the reason for a redisclosure
- Select one or more reasons to indicate why the redisclosure is being made.
- If you select the Other option, enter a description in the text box.
The Changed Circumstance section enables users to enter or edit details about a changed circumstance that results in a redisclosed Loan Estimate.
Indicate a changed circumstance
- Select the Changed Circumstance checkbox.
- The Changes Received Date is populated automatically. To change the date, type a new date or click the Calendar icon to select a date.
2. Click the Find icon to the right of the Changed Circumstance field to select a descriptions of the changed circumstance from a predefined list.
- To provide more flexibility for users indicating a changed circumstance, a new Show All COC Reasons checkbox is provided at the bottom of the list of changed circumstances provided when you click the Find icon. Select this checkbox to display all available changed circumstances (includes both LE and CD changed circumstances).
3. Enter comments as needed.
The area below the Reason section displays information about the most recent Loan Estimate disclosed to the borrower that has not been excluded from the timeline in the Disclosure Tracking tool. These fields are populated after a Loan Estimate has been disclosed to the borrower. The fields are read-only and cannot be edited.
- Last Sent Date – Date when the Loan Estimate was sent.
- By – Encompass user who sent the Loan Estimate.
- Sent Method – Method used to send the disclosure.
- Received Date – If the most recently disclosed version of the disclosure is the initial Loan Estimate, the LE Received Date from the Disclosure Tracking tool. If the most recently disclosed Loan Estimate is a revised Loan Estimate, the Revised LE Received Date from the Disclosure Tracking tool.
The area below the Intent to Proceed section records the borrower’s intent to proceed with the loan and provides information about the Loan Estimate that is being used for the loan. This section is enabled for editing only after a disclosed Loan Estimate has been received by the borrower (the current date is on or after the LE Received Date on the Disclosure Tracking tool for the most recently disclosed Loan Estimate).
Complete the Intent to Proceed section
- Select the Intent to Proceed checkbox.
2. When the Disclosed LE Snapshot window opens, select a previously disclosed Loan Estimate from the panel at the top of the screen, and then click OK.
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- The Loan Estimate sent on field is populated with the LE Sent date for the selected Loan Estimate, and the remaining fields in the Intent to Proceed section are populated based on the Disclosure Tracking tool information for the selected Loan Estimate. Changes made to this information on the Loan Estimate form are copied to the Disclosure Tracking tool, and changes made to this information on the Disclosure Tracking tool are copied to the Loan Estimate form.
3. To select another loan estimate, click the Find icon (magnifying glass) next to the Loan Estimate sent on field.
Looking for more information on handling Change of Circumstance in Encompass 360 or need help with implementing any technology solution within Encompass, leave us a message.
