Indiana Bankers Mega Conference 2017
2017 MEGA CONFERENCE
TRID: WHERE ARE WE NOW?
TILA REGULATION Z
Patti Joyner Blenden, CRCM
May 2017
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MORTGAGE LENDER ISSUES
INDUSTRY IS STILL AWAITING FINAL TRID AMENDMENTS FOLLOWING JULY 2016 PROPOSAL!!!!
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SALE PRICE OR ESTIMATED PROPERTY VALUE
§1026.37(A)(7)
 Purchase money mortgage = Sale Price
 If seller’s Sale Price is not yet known, use the estimated value of the
property used as the basis for the LE disclosures
 If personal property is included in Sale Price of Property, use that combined Sale Price
without any reduction for appraised or estimated value of personal property
 If loan is for a transaction without a seller (such as a refinance or a
construction loan where land already owned by borrower), use
Appraised Value or Estimated Value
 If Creditor has obtained or estimated valuation by issuance of LE, use that Appraisal
Value or Estimated Value. If none, use best info available.
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Comment §1026.37(a)(7)-1
TRID CONSTRUCTION LOAN: PROPERTY VALUE §1026.37(A)(7)
Transaction Examples
Loan Estimate Label
Valuation
Consumer owns land and proceeds
to construct the dwelling; Bank has
not obtained any valuation yet
PROP. VALUE
Estimate provided by customer at
application
Consumer owns land and proceeds
to construct the dwelling; Bank has
preliminary valuation
PROP. VALUE
Estimate obtained by bank to be
used in underwriting; If multiple
valuations, use best one available
Consumer purchasing land and will
construct dwelling; Bank not yet
obtained appraisal
SALE PRICE
Sales price of the land plus the
estimated value of dwelling based
on best information available
Consumer purchasing land and will
construct dwelling; Bank has
obtained multiple appraisals
Consumer purchasing land and
home is currently under construction
SALE PRICE
SALE Price
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Sales price of the land plus the
estimated value of dwelling based
on valuation used in underwriting
Sales price of the land plus the
estimated value of dwelling upon
completion of construction
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TRID LOAN PURPOSE
 Describe the consumer’s intended use for the loan per TRID definitions
 Purpose is disclosed using one of four descriptions, per this hierarchy!
 Purchase: Loan will be used to finance the acquisition of the identified Property
(collateral property)
 Refinance: Loan will be used to refinance an existing obligation that is secured by
the identified Property (even if creditor is not holder or servicer of original obligation)
 Construction: Loan will finance initial construction of a dwelling on property
disclosed on Loan Estimate
 Home Equity Loan: Loan will be used for any other purpose not listed in the
categories above
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TRICKY TRID PURPOSE CODES
4 TRID Purpose
Codes & Hierarchy
•Purchase
•Refinance
•Construction
•Home Equity
3 HMDA Purpose
Codes & Hierarchy
•Purchase
•Home Improvement
•Refinance
If multiple purpose loans, use the highest ranking purpose category above
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CONSTRUCTION LOAN LE
ESTIMATED TAXES, INSURANCE AND ASSESSMENTS
 The creditor discloses estimates based on the best information reasonably available at
the time of the disclosure. The reasonably available standard requires a creditor to act
in good faith and to exercise due diligence in obtaining the information.
 Comments 17(c)(2)(i)-1 and 19(e)(1)(i)-2
 The estimated property taxes to be disclosed for all TRID transactions, including
construction loans, must reflect the taxable assessed value of the real property securing
the transaction after consummation. This includes the value of any improvements on the
property or to be constructed on the property, if known, regardless of whether the
construction will be financed from the proceeds of the loan. §1026.37(c)(5)(i)
 The disclosed estimated homeowner's insurance must reflect the replacement costs of
the property during the initial year after the transaction. §1026.37(c)(5)(ii)
 The estimated taxes and homeowner's insurance must be disclosed as a monthly
amount even if no escrow account is established. §1026.37(c)(4)(ii)
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SIX EVENTS JUSTIFYING REVISED LOAN ESTIMATES
 The law sets out 6 events that justify a revised Loan Estimate for purposes of
resetting fees and performing the transaction’s good-faith analysis of fees within
allowed tolerances. Those 6 events include:
 Only time Revision is Required: Interest rate lock
 Changed circumstances increasing settlement charges
 Changed circumstances impacting the consumer’s loan eligibility or the value of the
property securing the loan
 Consumer-requested changes
 Expiration of the original Loan Estimate
 Construction loan settlement delays
 Revised Loan Estimates may be required, used to reset tolerances if allowed, or
reissued only as clarification for the consumer’s benefit without tolerance reset
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MORTGAGE LOAN LE – WRITTEN LIST OF PROVIDERS
 Written List of Providers must match the Loan Estimate!
 If a consumer is permitted to shop for a settlement service, TRID’s
§1026.19(e)(1)(vi)(C) requires the creditor to provide the consumer with a written
list identifying at least 1 available provider of that service and stating the
consumer may choose a different provider for that service.
 Settlement service providers identified on the written list must correspond to the
settlement services for which the consumer may shop as disclosed on the Loan
Estimate, Loan Costs, “C. Services You Can Shop For.”
 Creditor does not have to list services that are required – it’s optional!
 Is your process effective for ensuring the unique terms for each transaction is
correctly reflected in the document disclosures?
 Geographic concerns remain high when the property is out of market!
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MORTGAGE LOAN LE – WRITTEN LIST OF PROVIDERS PROPOSAL
 Current: If the creditor permits the consumer to shop but fails to provide
the list required, good faith is determined pursuant to §1026.19(e)(3)(ii)
instead of §1026.19(e)(3)(iii) regardless of the provider selected by the
consumer, unless the provider is an affiliate of the creditor in which case
good faith is determined pursuant to §1026.19(e)(3)(i).
 Proposal: If the creditor permits the consumer to shop consistent with but
fails to provide the list required or the list does not comply with the
requirements, good faith is determined under §1026.19(e)(3)(i) instead of
§1026.19(e)(3)(iii) regardless of the provider selected by the consumer.
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SETTLEMENT AGENT ISSUES
 Settlement agents must provide final CD to Seller for Purchase transactions
(§1026.19(f)(4))
 CD must be provided to Seller at or before consummation
 Not acceptable to substitute ALTA Settlement Statement for the CD
 Not allowed to use the previous HUD-1
 Required to provide Lender with copy of Seller’s CD if Borrower and Seller information is
separately disclosed
 All Closing Disclosures must reconcile and balance, including
 Lender’s CD
 Seller’s CD
 Settlement Agent’s settlement statement
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MORTGAGE LENDING CD – BORROWER & SELLER COPIES
Seller’s Closing Disclosure
 Creditor's copy. When the consumer's and seller's disclosures under this
paragraph (f) are provided on separate documents, as permitted under
§1026.38(t)(5), the settlement agent shall provide to the creditor (if the
creditor is not the settlement agent) a copy of the disclosures provided
to the seller under paragraph (f)(4)(i) of this section.
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MORTGAGE LENDING CD – BORROWER & SELLER COPIES
 There is still great hesitancy by many lenders to provide disclosure copies
to the other transaction parties unless the consumer borrower has
specifically authorized it, or even more likely, the consumer has
personally provided the copies on his or her own
 Despite the proposed clarifications offered by the CFPB in July 2016,
many lenders and investors remain very uneasy about privacy violations
in sharing the information per Gramm Leach Bliley Act.
 Informal assurance or proposals from the CFPB are simply not good
enough. Waiting to see regulatory and statutory changes.
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MORTGAGE LENDING CD – OTHER COSTS
Real estate commissions
 The amount of real estate commissions pursuant to §1026.38(g)(4) must
be the total amount paid to any real estate brokerage as a commission,
regardless of the identity of the party holding any earnest money
deposit.
 Additional charges made by real estate brokerages or agents to the
seller or consumer are itemized separately as additional items for services
rendered, with a description of the service and an identification of the
person ultimately receiving the payment.
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MORTGAGE LENDING CD – CONTACT INFORMATION
 License number or unique identifier
 Section 1026.38(r)(3) and (5) requires the disclosure of a license number
or unique identifier for each person (including natural persons) identified
in the table who does not have a NMLSR ID if the applicable State,
locality, or other regulatory body with responsibility for licensing and/or
registering such person’s business activities has issued a license number
or other unique identifier to such person under §1026.38(r)(3) and (5).
Look to state licensing requirements to determine if a number is
available.
 Real estate agents
 Title agents
 Licensed escrow agents
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TRID RECORD RETENTION – CLOSING DISCLOSURE
 A creditor shall retain each completed disclosure required under
§1026.19(f)(1)(i) or (f)(4)(i), and all documents related to such disclosures, for
five years after consummation, notwithstanding paragraph (ii)(B) of this section.
 Examples:
i.
Amortization Schedules (Loam Terms, Projected Payments, Loan Calculations)
ii.
Calculation of Taxes, Insurance & Assessments
iii.
All documentation supporting revisions to Loan Estimates or Closing Disclosures
iv.
Each version of the application, the LE or CD and whether the revised LE or CD reset
tolerances or did not reset tolerances
v.
Customer communication
vi.
All invoices, payment and funding records (Closing Costs and Cash to Close)
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REGULATION Z (§1026.19(F)(2)
 Subsequent Changes
i.
Changes before consummation not requiring a new waiting period
ii.
Changes before consummation requiring a new waiting period
iii. Changes due to events occurring after consummation
iv. Changes due to clerical errors
v. Refunds related to the good faith analysis
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REGULATION Z (§1026.19(F)(2) – SUBSEQUENT CHANGES
Changes before consummation not requiring a new waiting period
i.
If the disclosures provided become inaccurate before consummation,
the creditor shall provide corrected disclosures reflecting any changed
terms to the consumer so that the consumer receives the corrected
disclosures at or before consummation. The creditor shall permit the
consumer to inspect the disclosures, completed to set forth those items
known to the creditor at the time of inspection, during the business day
immediately preceding consummation, but the creditor may omit from
inspection items related only to the seller’s transaction.
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REGULATION Z (§1026.19(f)(2) – SUBSEQUENT CHANGES
Changes before consummation requiring a new waiting period
ii.
If one of the following disclosures provided becomes inaccurate in the
following manner before consummation, the creditor shall ensure that the
consumer receives corrected disclosures containing all changed terms in
accordance with the requirements of paragraph (f)(1)(ii)(A) of this section:
A.
The APR disclosed under §1026.38(o)(4) becomes inaccurate, as defined in §1026.22.
B.
The loan product is changed, causing the information disclosed under §1026.38(a)(5)(iii)
to become inaccurate.
C.
A prepayment penalty is added, causing the statement regarding a prepayment
penalty required under §1026.38(b) to become inaccurate.
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REGULATION Z (§1026.19(F)(2) – SUBSEQUENT CHANGES
Changes due to events occurring after consummation
iii. If during the 30-day period following consummation, an event in
connection with the settlement occurs causing the disclosures to
become inaccurate, and such inaccuracy results in a change to an
amount actually paid by the consumer, the creditor shall deliver or
place in the mail corrected disclosures not later than 30 calendar days
after receiving information sufficient to establish that such event has
occurred.
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REGULATION Z (§1026.19(F)(2) – SUBSEQUENT CHANGES
Changes due to clerical errors
iv. If disclosures contain non-numeric clerical errors, creditor must deliver or
place in the mail corrected disclosures no later than 60 calendar days
after consummation.
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REGULATION Z (§1026.19(F)(2) – SUBSEQUENT CHANGES
Refunds related to the good faith analysis
v. If amounts paid by the consumer exceed the amounts specified under
paragraph (e)(3)(i) or (ii) of this section [comparison of CD fees to LE
fees for zero, 10% cumulative, or unlimited tolerance], the creditor
complies with paragraph (e)(1)(i) of this section if the creditor refunds
the excess to the consumer no later than 60 calendar days after
consummation, and the creditor complies if the creditor delivers or
places in the mail corrected disclosures that reflect such refund no later
than 60 calendar days after consummation.
The “good faith analysis” is all about whether the fee amounts are within
the appropriate levels for the 3 fee tolerance categories!
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https://www.nar.realtor/sites/default/files/reports/2016/2016q3-mortgage-originators-survey-11-15-2016.pdf
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NAR 3RD QUARTER 2016 SURVEY OF MORTGAGE ORIGINATORS
 The share of transactions delayed due to TRID rose to 2.6 %, but both TRID and
non-TRID cancelations fell.
 More than half of lenders passed TRID-related costs to consumer with a
weighted average increase of $220.
 Only 16.7 % of participating lenders shared the closing disclosure (CD)
unconditionally with REALTORS®, while 50 % did not share under any
circumstances.
 83.3 % of respondents indicated that the CFPB’s July clarification sharing did not
impact their decision to share the CD. Several lenders indicated that more
clarification was needed or that they were not aware of the CFPB’s statement.
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https://www.nar.realtor/sites/default/files/reports/2016/2016q4-mortgage-originators-survey-02-01-2017.pdf
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NAR 4TH QUARTER 2016 SURVEY OF MORTGAGE ORIGINATORS
 55.6% of lenders indicated some level of problems getting appraisals, with 11.1%
indicating it was significant.
 Lenders viewed fewer new appraisers, a reluctance to perform certain
appraisals, and high refinance volumes as the main drivers of the shortage
 However, 27.8% of lenders do not accept appraisals in which any part is
performed by a trainee, while 44.4% require direct supervision of all aspects
performed by a trainee.
 9.8% of respondents had faced a “rush fee” in which fees are increased to
meet a time constraint. In this sample, rush fees averaged 37.1% higher.
 16.7% of respondents felt that rising rates will weaken demand for purchase
mortgages, but 44.4% felt that strong employment and income growth will
partially offset rising rates
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http://www.fanniemae.com/resources/file/research/mlss/pdf/
mortgage-lender-sentiment-survey-findings-q12017.pdf
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FANNIE MAE MORTGAGE LENDER SENTIMENT SURVEY
QUARTER 1 2017, PUBLISHED MARCH 27, 2017
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FANNIE MAE MORTGAGE LENDER SENTIMENT SURVEY
QUARTER 1 2017, PUBLISHED MARCH 27, 2017
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TRID COMMON COMPLIANCE MISTAKES
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TRID COMMON ERRORS
 Consistent fee names between Loan Estimate and Closing Disclosure
 Typographical issues that are technical violations
 Blank versus 0 or Not Applicable
 Hyphens and other punctuation marks
 Incorrect number of columns in the Projected Payments table
 Prepaid property taxes not in the 0% tolerance category per CFPB formal
clarification
 Total of Payments calculation errors for the new disclosure item
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TRID COMMON ERRORS (continued)
 Calculating Cash to Close table issues, especially for FHA loans
 Uses note amount instead of base loan amount for closing costs financed and down
payment calculations; also closing costs financed do not include financed upfront MIP
 Escrowed Property Costs over Year 1
 Loan Estimate follows TRID rules and Closing disclosure follows RESPA Escrow rules
 The infamous “Black Hole”
 Comment 19(e)(4)(ii)-1: If there are less than 4 business days between revision of the
disclosures is required to be provided pursuant to §1026.19(e)(4)(i) and consummation,
creditors comply with the requirements of §1026.19(e)(4) (Loan Estimate] if the revised
disclosures are reflected in the disclosures required by §1026.19(f)(1)(i) [Closing Disclosure] .
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REGULATOR AND INVESTOR FOCUS
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REGULATOR CONCERNS
 Consumer harm remains a high priority as anticipated!
 True to their word, the regulatory exam teams focused on compliance
management systems in early TRID exams
 Compliance with the TRID rules is now a part of the consumer
compliance examination
 Most of my bank clients are reporting fair and balanced reviews while
the examiners continue to learn the rules, just like the industry
 Audits continue to identify a lot of technical clerical violations (fee
names, consistency between personnel, geographic differences in
services and fees to be provided in the local area, etc.)
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INVESTOR CONCERNS
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TRID CIVIL LIABILITY
 TRID Rule does not clarify which statutory liability applies to different parts
of the TRID Rule or to the TRID forms
 TRID preamble directs us to look at the statutory authority utilized for
each provision. CFPB felt this was sufficient guidance for the courts,
industry and consumers. REALLY????
 CFPB issues Loan Estimate and Closing Disclosure with Truth in Lending
Act statutory citations listed on each
 LE: http://files.consumerfinance.gov/f/documents/201605_cfpb_loan-estimate-withtruth-in-lending-act-disclosure-citations.pdf
 CD: http://files.consumerfinance.gov/f/documents/201605_cfpb_closing-disclosurewith-truth-in-lending-act-disclosure-citations.pdf
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TRID TOLERANCE CURES
 These tolerance cures do not override any statutory cure provisions that
are also available to the consumer; these are in addition to legal cures.
 TRID tolerance violations are addressed in §1026.19(f)(2)
 Consumer is entitled to a refund within 60 calendar days after consummation along
with a corrected Closing Disclosure. CFPB interpreted this in their calendar to be a
“consumer’s receipt” requirement
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TRID STATUTORY CURES
 One of the biggest investor and lender issue today remains a “gray area”
 Two primary TILA areas address potential damages for legal violations
 TILA §130(b) [15 U.S.C. § 1640(b)]
 Borrowers must be notified of an error within 60 calendar days of discovery of an error, prior to
notification by borrowing including a lawsuit, and “make whatever adjustments in the appropriate
account are necessary to assure that the person will not be required to pay an amount in excess of
the charge actually disclosed, or the dollar equivalent of the annual percentage rate actually
disclosed, whichever is lower”
 TILA §130(c) [15 U.S.C. § 1640(c)]
 Creditors are given a legal defense for unintentional bona fide errors, excluding errors of legal
judgment. Statute provides a useful example such as “computer malfunction and programming.”
Creditors must prove what has been historically difficult to prove:
 Error was unintentional and was a clerical error
 Procedures designed to avoid and prevent errors of this type were regularly maintained
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CFPB
disclosures
with
statutory
citations
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 Cordray’s
letter to the
Mortgage
Bankers
Association,
December
2015
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CFPB CORDRAY’S LETTER TO MORTGAGE BANKING ASSOCIATION
REGARDING TILA LIABILITY AND CURES
 How much can we rely on the letter when Cordray himself said in the
PHH decision that an unpublished HUD letter was “not in such a form as
to be binding on any adjudicator”
 Statement regarding statutory damages not applying to new DoddFrank Act disclosures
 Liability after Foreclosure, Escrow Account….
 Uncertainties regarding curing LE errors with CD
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CFPB CORDRAY’S LETTER TO MORTGAGE BANKING ASSOCIATION
REGARDING TILA LIABILITY AND CURES
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CFPB CORDRAY’S LETTER TO MORTGAGE BANKING ASSOCIATION
REGARDING TILA LIABILITY AND CURES
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CFPB CORDRAY’S LETTER TO MORTGAGE BANKING ASSOCIATION
REGARDING TILA LIABILITY AND CURES
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TRID BEST PRACTICES
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TRID BEST PRACTICES
 Set parameters for as many bank policy decisions as possible in your TRID
loan origination systems. Reduce the potential human errors as much as
you possibly can, making sure parameters match bank policy!
 Centralize important TRID processes and discretionary decisions to the
greatest extent possible! Lenders and brokers should not determine
whether a valid change of circumstance exists and the impact on
disclosures (i.e. reissue and reset tolerances, etc.) These decisions are
best made by a smaller number of individuals with appropriate expertise.
 Generate Loan Estimates and Closing Disclosure forms by an
experienced centralized processing group.
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TRID BEST PRACTICES (CONTINUED)
 Maintain a strong pre-closing review of all LE and CD documents to
identify as many errors and violations BEFORE consummation as possible!
 Require that all loans also undergo a post-closing compliance review in
addition to your normal quality control reviews. TRID specific cures
provide the best protections post-closing if the errors are identified no
later than 60 calendar days after closing.
 Finding and correcting errors immediately after loan closing may not stop
restitution of incorrectly disclosed fees, but it will certainly help the lender
reduce the likelihood of enforcement actions and private litigation.
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TRID BEST PRACTICES (CONTINUED)
 Make it a standard practice to issue a new Written Service Provider List (WSPL)
each and every time you issue a revised Loan Estimate.
 The TRID regulations require a WSPL when the initial Loan Estimate is provided to
disclose to applicants at least one available provider of every settlement
service. However, the TRID regulations do not address whether the lender
should issue a new list when a new provider is introduced due to a changed
circumstance or a borrower- initiated change. If no new WSPL is provided
including the new provider, the consumer will be assumed to not have the
opportunity to shop for the newly added service, and the fees will be included
in the “zero tolerance” category.
 The best practice to protect the creditor’s ability to minimize any fee refunds is
to ensure that an accurate and complete WSPL is issues with each LE!
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TRID BEST PRACTICES (CONTINUED)
 Ensure that your loan origination system has a thorough and retainable audit
trail. Identify all user note capability and indicate the sequence of events,
consumer and third party communications and other items documenting loan
changes from cradle to grave in the origination process.
 Property information provided by the Borrower, the Seller or the Realtor
 Appraisal results, including property specific and market adjustments
 Change in loan amount or loan types or any other transaction information
 Due to the complexity of the TRID rules, periodically review the entire mortgage
origination compliance program every 3 or 6 months to correct anything
quickly. Identify gaps in your processes and fix them immediately!!! Report
findings to management and the board.
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PATTI JOYNER BLENDEN, CRCM
[email protected]
WWW.FINSOLINC.COM
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ActionTraining
TRID
Shopping for Settlement Services §1026.19(e): Updated
by Patti Blenden
he TILA RESPA Integrated
Disclosures (TRID) rules facilitate consumer selection of
service providers if an applicant is
allowed or required to select the
vendor. To comply with TRID, a
written list must be prepared and
provided in good faith to mitigate
exposure to unwanted tolerance
variances.
A compliant Written List of
Providers (Sample Form H-27)
T
Creditor Action
must include at least one provider
available to perform each shoppable
service in the applicable geographic
area AND state that the consumer
may choose a different provider for
that service. Beware, if listing only
one provider, you run the risk that
provider is unavailable (e.g., retired,
assignment outside of provider’s
market, etc.), making your list
non-compliant! The written list must
be submitted simultaneously, but sepa-
Applicant Action
rately, from the Loan Estimate.
Here are a few tips to help you in
complying with TRID’s very
important shopping, tolerance
calculation, and disclosure rules.
The CFPB issued proposed
TRID amendments in July, 2016.
We have updated this chart to
reflect an important clarification impacting your good faith
determination of allowable
tolerances.
Loan Estimate: Page 2
Closing Cost Details
Tolerance
Closing Disclosure: Page 2
Closing Cost Details
Service required by Creditor
Provider required by Creditor
None required
Section B: Services You
Cannot Shop For
0.00%
Section B: Services Borrower
Did NOT Shop For
Service required by Creditor
Provider NOT required by Creditor
Provider IS an affiliate of Creditor
or Mortgage Broker
Written list of providers compliant
Selects affiliate
provider from
Creditor’s compliant
shopping list
Section C: Services You
Can Shop For
0.00%
Section B: Services Borrower
Did NOT Shop For
Service required by Creditor
Provider NOT required by Creditor
Provider NOT an affiliate of
Creditor or Mortgage Broker
Written list of providers compliant
Selects non-affiliate
provider from
Creditor’s compliant
shopping list
Section C: Services You
Can Shop For
10.00%
Section B Services Borrower
Did NOT Shop For
Service required by Creditor
Provider NOT required by creditor
Written list of providers compliant
Consumer doesn’t
choose; Creditor
selects provider from
Creditor’s compliant
shopping list
Section C: Services You
Can Shop For
0.00% if
affiliated;
10.00% if an
unaffiliated
provider
Section B: Services Borrower
Did NOT Shop For
Service required by Creditor
Provider NOT required by Creditor
Written list of providers compliant
Consumer selects a
provider NOT on the
Creditor’s compliant
shopping list
Section C: Services You
Can Shop For
Unlimited;
No
tolerance!
Section C: Services Borrower
Did Shop For
Service required by Creditor
Provider NOT required by Creditor
Written list of providers NOT
compliant
Regardless of
applicant’s choice of
provider on or not on
non-compliant list,
Creditor’s list
non-compliant
Section C: Services You
Can Shop For
0.00%
Section C: Services Borrower
Did Shop For
Service NOT required by Creditor
Provider NOT required by Creditor
Selects affiliate or
non-affiliate provider
Section C: Services You
Can Shop For
Note 1
Unlimited;
No
tolerance!
Section C: Services Borrower
Did Shop For
Note 1: The CFPB issued proposed TRID amendments on July 28, 2016. Included in the proposal are many items identified as clarifications or
technical changes rather than major policy changes. One of the clarifications that we feel confident to rely now, pending final amendments, is the
clarification by the CFPB of the impact of a non-compliant list on shoppable services. The CFPB clarified that if a list was not provided, was
noncompliant or was provided late, the otherwise 10% aggregate tolerance item would revert to 0.00% tolerance - no increases whatsoever.
COMPLIANCE ACTION
September 23, 2016
PAGE 4
VOLUME 21, NUMBER 10
https://www.bankersonline.com/ca