- Business Rules
It’s understood that if a text field is blank then do not use N/A, but if a numeric field is blank should we use 0 (zero)?It depends on the section of the Loan Estimate. Certain sections, like the numeric fields for the Projected Payments Table, require "0" in some circumstances and "-" in others. In the Calculating Cash to Close section, "$0" for no value appears to be appropriate. However, in the Loan Costs and Other Costs sections, it appears if a hardcoded named fee is zero; it would be left blank, and not contain a "$0" or "0". See Model H-24(B). See also Commentary ¶37-1. Where a disclosure is not applicable to a particular transaction, unless otherwise provided by §1026.37, form H-24 of appendix H to this part may not be modified to delete the disclosure from form H-24, or to state "not applicable" or "N/A" in place of such disclosure. The portion of the form pertaining to the inapplicable disclosure may be left blank, unless otherwise provided by §1026.37. For example, in a transaction for which the consumer does not pay points to the creditor to reduce the interest rate, the amounts required to be disclosed by §1026.37(f)(1)(i) may be left blank on form H-24. As provided in §1026.37(i) and (j), however, the adjustable payment and adjustable interest rate tables required by those paragraphs may be included only if those disclosures are applicable to the transaction and otherwise must be excluded.
Citation(s): Commentary ¶37-1; Commentary ¶37(c); Model form H-24(B)
CFPB announcement regarding the delay of TRID
The full statement from CFPB Director Richard Cordray can be viewed here