We’re a few years into the TRID rule implementation, and now we have the “TRID 2.0” rules from the CFPB. Also the Dodd-Frank reform bill signed into law last May mandates some further revisions. How are things going for you? You’ve probably run into many of the same issues many of your peers are, and you likely have many of the same questions. Hopefully it comforts you to know you’re not alone! The regulatory agencies have thus far provided mostly “good faith” compliance exams, and have not yet begun close inspections of the intricacies of TRID. That is beginning to change. The TRID 2.0 changes were meant to correct some outstanding issues with the regulation and make compliance easier. However, they’re very detailed. As well, the CFPB has finally dealt with the “black hole,” which arose during the closing process.
This webinar is intended to review and discuss many of the major issues lenders are facing with TRID, including the recent changes, black hole, and some continued unresolved questions and how to deal with them. As well, there are many pain points in both the new loan process and disclosures that we’ll review in order to formulate some best practices. We’ll talk specifics about the Loan Estimate and Closing Disclosure, as well as some of the frequent violations discovered so far.
- Recent amendments to the regulation: TRID 2.0
- Dodd-Frank reform provisions – what will they do? What can we expect?
- Criticality of meeting the timing and delivery requirements of the Loan Estimate and the Closing Disclosure
- Ensuring your application process is sound
- Issues around the content of the Loan Estimate and the Closing Disclosure – specific line items and questions
- Variations/tolerance issues – what is the “fee tolerance baseline”? When we can issue a revised LE (and/or CD?) How and when should we remediate?
- Documenting changed circumstances – perhaps the most important thing you can do
- Changes before closing – is a new waiting period required?
- Pre-disclosure requirements – collecting fees and obtaining “intent to proceed”
- Pre-qualifications and preapprovals (are there such things anymore?)
- Keeping straight the business day differences and the mailing rule
- When to rely on automation vs. when not to
- Proving your good faith efforts to comply
- And much more
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