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Many Lenders Aren’t Ready For TRID

Would it be an over-statement to say that the mortgage industry is in a state of chaos? Probably. Nonetheless, many are very concerned about how the Consumer Finance Protection Bureau’s (CFPB) mandated TILA-RESPA Disclosure Rule (TRID) will forever change the space. The deadline for compliance is August 1 and it doesn’t look like the CFPB is going to be granting any extensions.

“Successfully meeting the CFPB’s TILA-RESPA Integrated Disclosure Rule by the August 1 deadline is obviously a major concern for lenders,” stressed Justin Glass, Chief Digital Officer at United Wholesale Mortgage (UWM). “We are already in testing with our compliance and business teams. Our broker and correspondent partners know that they are in good hands when doing a loan with us. We’re ahead of the curve for August 1.”

It is safe to say that every lender is very concerned about being in compliance with the new disclosures. However, we at PROGRESS in Lending thought that we would dive a little deeper into this situation. We wondered how many other lenders, aside from UWM already have the new disclosures and are actually testing them already. In the end, this change is not just about the disclosures, it’s about how they are produced and presented.

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After informally polling several lenders, we found that two-thirds (66%) in fact have not gotten the new disclosures from their document preparation or loan origination system providers. This is by no means a scientific study, but the fact that so many lenders are not already testing is a problem.

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So, how do lenders get up to speed and ensure compliance on day one?

“In today’s regulatory environment, it’s more important than ever to make sure you are picking the right partners that can quickly deliver accurate solutions to meet your compliance challenges,” answered Dan Jones, Vice President of Technology at Churchill Mortgage. “At the same time, don’t assume those partners always have the best channels of communication between them. Be sure to step into the process and make sure all of your partners are working together to deliver the overall compliance package that you need.”

Jones is 100% correct. Too often lenders outsource everything to the vendor and just assume that the vendor is taking care of everything. That’s not always the case. Vendors are stressed, too.

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Think about it: A lot of lenders have exited the space over the past few years, which means that vendors are fighting for more business when there are fewer prospects to actually attain new business. Also, the onslaught of new rules means that vendors are having to invest more money into updating their solutions just to ensure that their clients are in compliance.

What does all of this mean? The successful mortgage lender has to engage more with their vendors to make sure that their vendors will be in compliance and that they will be able to deliver the new disclosures early enough for the lender to actually test them out. Now is not the time to be shy. Now is the time to more directly engage with all of your vendors.

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Some Vendors Are Ready For TRID

While there have been rumors circulating that some technology vendors may not be ready for the august 1st deadline, others are touting the fact that they are already good to go. I reported earlier that ASC’s Power Lender LOS, transaction management expert CSi, and document compliance provider DocMagic have publically said that their solutions are already in the hands of lenders. Now, eLynx has announced that its Expedite ID (Integrated Disclosures), a compliance solution that fulfills lenders’ requirements for complying with the CFPB’s TILA/RESPA Integrated Disclosures (TRID) rule on August 1, 2015, is ready, as well. New compliance features, combined with the capabilities of eLynx’s Expedite services platform, provide lenders with a compliance solution for TRID while enhancing quality throughout the loan lifecycle.

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Expedite ID unites TRID-specific functionality with the proven foundation of eLynx’s collaboration services which are already in production, including the Expedite suite of integrated on-demand services; eCN, the electronic closing network used by over 85,000 registered closing professionals; and Expedite Inbox, a lender-branded consumer portal that streamlines interactions with consumers. TRID compliance capabilities added to eLynx production services include:

>> The ability to obtain fees from multiple sources, including third party providers, and present them to lenders for final determination and document generation

>> TRID-specific electronic collaboration capabilities to assist the exchange of fee data between lenders and settlement agents

>> Full support for capturing consumer consent and complying with new waiting periods and variance limits

>> Pre-funding and post-close audit functions to reconcile the final loan package with the lender-approved loan and ensure post-close compliance and quality

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To help them prepare for the transition to TRID, eLynx customers will be getting hands-on experience with Expedite ID via a secure test environment soon. Additional TRID-related enhancements are in development and will be announced over the next several months.

“Having a long-established consumer portal with the Expedite Inbox and a huge, existing database of registered closing professionals gives us a definite advantage in helping our customers prepare for TRID. There’s less worry about getting agents registered and more emphasis on the collaboration process itself,” said Sharon Matthews, eLynx president and CEO.

Matthews noted that Expedite ID can be deployed as a complete end-to-end solution or components can be deployed individually to meet specific lender requirements. “With the Expedite platform, customers get a full compliance solution that supports the entire loan cycle through post-close, and provides integrated, end-to-end documents and data,” Matthews said.

About The Author

[author_bio]

Tony Garritano
Tony Garritano is chairman and founder at PROGRESS in Lending Association. As a speaker Tony has worked hard to inform executives about how technology should be a tool used to further business objectives. For over 10 years he has worked as a journalist, researcher and speaker in the mortgage technology space. Starting this association was the next step for someone like Tony, who has dedicated his career to providing mortgage executives with the information needed to make informed technology decisions. He can be reached via e-mail at tony@progressinlending.com.

TRID Compliance Can Be Easy As Pie

DocMagic, Inc. will launch a Collaborative Closing Platform for the mortgage industry. Why is this significant? The solution is comprised of a secure, seamless and dynamic web-based portal that efficiently and expeditiously helps lenders comply with the TILA-RESPA Integrated Disclosure (TRID) rule that becomes effective on August 1. Here’s how it works:

DocMagic’s Collaborative Closing Platform enables streamlined, real-time exchange of information between lenders, settlement agents and their associates via a secure web portal designed to electronically access, edit, validate and approve both data and documents. As a result, the coordination of all closing costs and audits of critical disclosure details are addressed prior to closing and in full compliance with TRID.

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“Our Collaborative Closing Platform brings all of the necessary closing components and parties together to effectively assist lenders in complying with TRID in a very efficient, timely fashion,” said Dominic Iannitti, president and CEO of DocMagic. “With one simple click, lenders can invite their settlement providers to view and update disclosure data, which is automatically analyzed by DocMagic’s comprehensive Audit Engine in preparation for final approval by the lender.”

The solution utilizes version 3.3 of the new MISMO standard that is needed for TRID to bi-directionally and securely pass data between parties. DocMagic’s Audit Engine automatically tracks RESPA tolerance levels, changes in fees and related approvals to ensure compliance with applicable regulations. Each step in the process is tracked and stored within the secure environment.

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Approved parties that are involved in the process can view a full electronic audit trail history of compliance, workflow and document management, which is securely captured and housed in a centralized area for easy access and reporting. Inside the secure platform parties with appropriate permissions can access shared documents, enter and adjust data, view the closing disclosure in real-time as it is modified, and communicate via an integrated chat system.

DocMagic’s Closing Collaboration Platform leverages its eSign technology to deliver and facilitate the electronic signing of the closing disclosure and related documentation. The solution also provides a bridge that can seamlessly integrate with title, closing and lender LOS systems. The company says that in addition to lenders and settlement providers being able to utilize the platform, other relevant technology vendors can also take advantage of the solution to review and share data and documents.

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Advancing TRID Education

LoanLogics understands that meeting the deadline for the TILA-RESPA Integrated Disclosures (TRID) requires a lender’s technology, document providers and staff to be prepared, according to their quick reference compliance guide, “Are You TRID Ready?” The deadline to comply with TRID is August 1, 2015. Here’s their solution:

“In my work consulting with lenders on the challenges of complying with TRID, I came to the conclusion that a quick reference guide and interactive online tools would help them and their staff better understand the new disclosure requirements. Anything that can help individuals get up to speed more quickly will benefit them, as well as the entire mortgage industry,” said Mike Vitali, the SVP/Chief Compliance Officer at LoanLogics and author of the guide.

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The purpose of the TRID guide is to provide a useful lender resource that is easy to follow and helps relieve some of the pressure they are feeling regarding getting prepared. That is critical; because of how pervasively this impacts a lender’s operations and the challenge of meeting the deadline and staying compliant once the rule goes live. Additionally, this guide may be downloaded and distributed to staff as a handy quick reference tool for day-to-day reference when needed.

“We’ve provided this reference guide, as well as online interactive tools, that will address many of the concerns Lenders face in preparing their staff to comply with these new rules,” said Vitali.

Tracking versions of the new disclosures, as well as timing definitions, is a role for technology. Lenders can’t rely on humans to get this correct. Open infrastructure technology with active alerting and dynamic workflow driven by rules will become the standard.

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This also becomes one more reason for pre-close audit reviews to enable tighter control of data and details. Even as loans are boarded to servicing, it will no longer be satisfactory to merely check for the presence of documents. Instead, systems must also check for correctness and track versions.

Some of the topics covered in the guide and the interactive website include:

>> A detailed explanation of both the new Loan Estimate and Closing Disclosure forms.

>> Interactive tools with line-by-line references for how to complete the new disclosure forms.

>> A sample TRID disclosure calendar.

>> LoanLogics newsletter articles with perspectives on TRID compliance and questions lenders need to consider regarding their TRID readiness.

To interact with this free on-line resource, go to Loanlogics.com/TRID.

About The Author

[author_bio]

Tony Garritano
Tony Garritano is chairman and founder at PROGRESS in Lending Association. As a speaker Tony has worked hard to inform executives about how technology should be a tool used to further business objectives. For over 10 years he has worked as a journalist, researcher and speaker in the mortgage technology space. Starting this association was the next step for someone like Tony, who has dedicated his career to providing mortgage executives with the information needed to make informed technology decisions. He can be reached via e-mail at tony@progressinlending.com.

Survey: Lenders Are Not Ready For TRID

In total, 41 percent of mortgage lenders report that they are not prepared to meet the August 2015 Truth in Lending Act and Real Estate Settlement Procedures Act (TILA-RESPA) Integrated Disclosure Rule, according to a recent survey conducted by Capsilon Corporation. Here’s the scoop:

The survey was conducted during the Mortgage Bankers Association’s (MBA’s) National Technology in Mortgage Banking Conference and Expo 2015, which took place March 29 through April 1 in Orlando, FL, and also online the week following the conference. Surprisingly, only 12 percent of respondents reported that their companies are “very prepared” to meet the August 2015 TILA-RESPA requirements.

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The survey, which polled more than 100 executives from leading mortgage lenders, also revealed that four out of five of the respondents believe that their companies’ loan production costs will continue to rise in 2015 versus 2014 as they increase focus on compliance-related activities, with 20 percent forecasting that their loan production costs will be “significantly” higher this year. In fact, 67 percent of the lenders reported that they have already hired additional in-house staff or engaged with outsourced staff to handle compliance-related activities, which is driving loan production costs higher.

This cost data is consistent with recent Mortgage Bankers Association data that reports total loan production expenses increased to $7,000 per loan in the fourth quarter of 2014, from $6,769 in the third quarter. The $7,000 figure represents an 18 percent increase in total loan production expenses over 2013, and a startling 36 percent increase over the total loan production expenses reported in 2012.

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“The survey results clearly indicate that many lenders don’t have the right technology in place to handle the requirements of TILA-RESPA, and are scrambling by hiring more labor to help close the gap, which only drives loan production costs higher,” said Sanjeev Malaney, CEO of Capsilon Corporation. “This is an unsustainable model, and lenders should be embracing technology to automate compliance and tolerance checks, not hiring more people.”

The survey also reveals that 82 percent of respondents plan to spend “significantly more” or “somewhat more” on technology in 2015 versus what they spent in 2014. This signals a growing recognition that the industry must implement technology solutions that ensure compliance as a means of reducing labor costs and decreasing total loan production costs.

About The Author

[author_bio]

Tony Garritano
Tony Garritano is chairman and founder at PROGRESS in Lending Association. As a speaker Tony has worked hard to inform executives about how technology should be a tool used to further business objectives. For over 10 years he has worked as a journalist, researcher and speaker in the mortgage technology space. Starting this association was the next step for someone like Tony, who has dedicated his career to providing mortgage executives with the information needed to make informed technology decisions. He can be reached via e-mail at tony@progressinlending.com.

Will Every LOS Be Ready For TRID?

Will every LOS be able to hit the August 1st deadline for the new RESPA-TILA disclosures? Probably not, but the rule will separate the good systems from the bad systems, and the good systems will be ready. For example, Associated Software Consultants, Inc., (ASC) developer of the PowerLender Loan Origination System, announced that its built-in Loan Estimate and Closing Disclosure documents solution has been delivered with the latest release, and users are implementing and testing the solution ahead of August deadline. Here’s the scoop:

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The release is the culmination of a year-long effort to prepare its user for the new disclosures. Introduced by the Consumer Financial Protection Bureau (CFPB) to replace the Truth-in-Lending disclosures, the Good Faith Estimate and the HUD-1 settlement for most loans, the Loan Estimate and Closing Disclosures will be mandatory for lenders beginning August 1, 2015.

PowerLender’s solution enables lenders to dynamically generate the Loan Estimate and Closing Disclosures from within PowerLender and allows them to exploit the efficiencies the LOS offers in terms of speed and accuracy. It uses an XML map to generate the disclosures, thus eliminating the need to maintain boilerplates and readies lenders for future delivery of Uniform Closing Dataset to the GSEs. The UCD is not yet required, but most agree it will likely be required soon. It will also have them ready well ahead of the deadline, averting the possible penalties, fines or loss of business.

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“The final piece of our Loan Estimate and Disclosures solution has been delivered to our users with the latest release of PowerLender,” said John Liston, Director of PowerLender Development. “Once user acceptance testing is performed, they will be ready to generate the CFPB integrated disclosures ahead of the August 2015 deadline, and at a minimal cost.”

About The Author

[author_bio]

Tony Garritano
Tony Garritano is chairman and founder at PROGRESS in Lending Association. As a speaker Tony has worked hard to inform executives about how technology should be a tool used to further business objectives. For over 10 years he has worked as a journalist, researcher and speaker in the mortgage technology space. Starting this association was the next step for someone like Tony, who has dedicated his career to providing mortgage executives with the information needed to make informed technology decisions. He can be reached via e-mail at tony@progressinlending.com.

Acquisition Ensures TRID Compliance

PROGRESS in Lending has learned that ComplianceEase, a provider of automated compliance solutions to the financial services industry, announced today that it has acquired the assets of Mortgage Banking Systems (dba ProClose) of McLean, Va., a provider of premier mortgage document preparation and closing software solutions for financial institutions. Here’s why:

The acquisition, which has been completed, will enable ComplianceEase to create a comprehensive and innovative solution that will help residential mortgage lenders comply with the TILA-RESPA Integrated Disclosure (TRID) rule that takes effect August 1, 2015. No sale price was disclosed. The Consumer Financial Protection Bureau’s (CFPB) new TRID rule will mandate new forms, the Loan Estimate and Closing Disclosure, and set new disclosure timelines and fee tolerances that must be followed in order to not trigger re-disclosure requirements.

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For the past 10 years, ComplianceEase and ProClose have partnered to deliver an integrated closing solution, known as Platinum, that drew from ComplianceEase’s enterprise-class compliance risk management expertise and ProClose’s advanced cloud-based document preparation system. As a result of this transaction that solution is being rebranded as SmartCloser.

The entire ProClose team is joining ComplianceEase. Christine Kirby, CEO and president of ProClose, will become vice president of ComplianceEase. No other terms of the transaction were announced.

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“While SmartCloser ensures that disclosures and closing documents are compliant, ComplianceAnalyzer continuously audits loan terms so that every transaction can be originated and closed in compliance with federal and state regulations,” said Kirby. “The combined solution provides ProClose’s clients and the rest of the industry with a unified platform for mortgage compliance. There isn’t a better, more dynamic or comprehensive compliance platform in the industry, and we are elated to bring our valued clients and strategic partners into the ComplianceEase family.”

“ComplianceEase has always been focused on providing our clients with comprehensive solutions that lower risk, improve productivity and reduce cost,” said John Vong, president and co-founder of ComplianceEase. “By adding a best-of-breed document platform to our suite of automated compliance products, we will be able to respond to all of the regulatory changes on the horizon, including the TRID rule, enabling lenders to focus on their core business.”

Vong continued, “Adding SmartCloser to our suite of solutions will allow our users to receive updates regarding any last minute changes that occur in the loan closing process, before these changes trigger re-disclosure requirements. So they’ll no longer need to rely on ‘eyeballing’ to compare disclosure and closing docs. Now it will occur automatically and seamlessly.”

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Vendor Collaborates With CFPB To Launch FAQ Website

PROGRESS in Lending has learned that Compliance Systems, Inc. (CSi), a provider of best-in-class financial transaction technology, officially launches its TRID FAQ website to provide key insights and dynamic solutions to address new regulatory requirements as lenders feel the deadline crunch.

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Lenders can’t afford to gamble on their TILA-RESPA Integrated Disclosures (TRID) solution. The CFPB’s TILA-RESPA Integrated Mortgage Disclosure Rule is 1,888 pages, with the dynamic disclosure specifications alone spanning hundreds of pages. The Model Forms must be followed exactly, and the Rule requires that many disclosures be presented to borrowers only when certain features apply to the loan.

Now lending institutions can benefit from CSi’s intensive research and ongoing conversation with the CFPB. The CSi TILA-RESPA Integrated Disclosures FAQ website includes answers to frequently asked questions regarding operational processes affected by the Rule as well as disclosure formatting concerns. Lenders can also take advantage of interactive Loan Estimate and Closing Disclosure samples that provide information about the Rule’s highly-dynamic disclosure requirements and describe how CSi’s TRID Solution guarantees compliant results.

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Chris Appie, Vice President and Counsel of CSi, noted, “CSi has actively collaborated with the CFPB throughout the development of our TRID Solution, identifying issues early and often with the Bureau. We have hard-won knowledge that we’re glad to share with our clients and others in the industry who are working to meet the August 1 deadline for implementation. Our FAQ site is intended as a living resource for their reference.”

About The Author

[author_bio]

Tony Garritano
Tony Garritano is chairman and founder at PROGRESS in Lending Association. As a speaker Tony has worked hard to inform executives about how technology should be a tool used to further business objectives. For over 10 years he has worked as a journalist, researcher and speaker in the mortgage technology space. Starting this association was the next step for someone like Tony, who has dedicated his career to providing mortgage executives with the information needed to make informed technology decisions. He can be reached via e-mail at tony@progressinlending.com.

TRID: Why Trekking Through The Weeds Is In Your Best Interest

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JoelHIf you open up an issue of Tomorrow’s Mortgage Executive from the last 12 months, odds are you’ll see articles about the upcoming TILA-RESPA Integrated Disclosure Rule (TRID). Lenders and settlement agents are struggling over who’s going to be responsible for preparing and delivering the Closing Disclosure. Providers are struggling because the Rule makes tracking fee tolerances more difficult and because the documents are dynamic and encompass hundreds of new data elements. And the industry is struggling: the Rule is going to be a much bigger challenge than most lenders realize. The CFPB estimated it will cost the industry at least $1B to implement, and by many accounts it’s going to be even more challenging than the CFPB’s January 2014 changes.

TRID represents an overhaul to the mortgage origination process, its players, and its technology, and if you’re subject to the Rule changes, you’ve probably been preparing for them for some time now. It’s likely that every TRID article you’ve read or seminar you’ve attended has focused on big changes with high industry visibility.

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That’s a good start, but the only way to ensure full compliance with TRID is to venture into the weeds to find the small changes, the changes that are so deeply embedded in the Rule that they could be easily overlooked.

Why Bother with Weeds?

Not only is the Rule lengthy (1,888 pages, to be exact), it’s more complicated than it seems. Let’s say you attended a seminar and reviewed a compliance guide. As a result, you may think that you have a handle on the requirements for your institution. Then, along the way, you find the regulatory text and commentary doesn’t exactly mean what you thought it did, at least as to how it impacts your business. So you do some more research and find that, although the CFPB has done an excellent job integrating the overlapping TILA and RESPA frameworks, the TRID Rule is not perfect. There are inconsistencies and gaps that can only be resolved through informal guidance. So you reach out to the CFPB for help, but you’re not able to get all the answers you need before the Rule is implemented.

What do you do?

You have to make judgment calls, and unless you’ve struggled through the thorns and brambles in the weeds, you won’t be able to back up those judgment calls with logical deduction if and when they are questioned. What started out as a straightforward, albeit lengthy, Rule has now turned into a thicket so twisted that you may not be able to find your way out without earning a few cuts and scrapes along the way.

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So, how do you leave the beaten path and climb into the weeds without getting completely lost? You plan ahead. Collaborate with other lenders and subject matter experts. Give yourself plenty of time to assess the impacts of small, less obvious changes so that you can make it out of the weeds unscathed.

A few things to keep in mind

In determining how the TRID Rule will impact CSi’s data-driven transaction risk management solution, we spent a great deal of time trudging through the weeds. This examination revealed a number of issues that lenders should be aware of in preparation for the August 1, 2015 deadline. For you, these may bring to light a compliance hurdle you have yet to consider, or they may simply demonstrate how deeply these hidden challenges are buried.

Do your own data analysis

Not only does TRID change the format in which information is disclosed, it also introduces an entirely new suite of data that must be collected, analyzed, disclosed, and transmitted.

Fannie Mae and Freddie Mac (GSEs) have also published a common dataset to implement the CFPB’s Closing Disclosure. The new Uniform Closing Dataset (UCD) is based on MISMO data standards. At some point in the future, the GSEs will require the UCD from lenders.

The CFPB, GSEs, consumers, lenders, and every other party in the mortgage process expect real-time, automated access to transaction data. That isn’t so bad until you consider that each party examines it differently. For example, the GSEs want to know a time period in months, while the CFPB requires that consumers read the time period in years and months, and loan origination systems may collect the time period as a number of days.

To fully comply with TRID and satisfy these various expectations, you must do your own data analysis. Many in the industry have chosen to rely solely on the UCD data elements to achieve compliance. The reality is, however, the UCD is neither finalized nor complete. Like the CFPB’s efforts to integrate overlapping regulatory frameworks, the UCD’s attempt to map all the data fields necessary for TRID is not without its limitations.

This leaves you with two choices when implementing TRID: (1) introduce potential compliance risk and rely solely on the UCD, filling in any data gaps as the UCD is revised; or (2) do your own data analysis to understand what data must be collected, analyzed, disclosed, and transmitted to comply with TRID.

The definition of “dynamic document” is about to change

The TRID Rule contains hundreds of pages of dynamic disclosure requirements that will prove challenging to some providers of document solutions.

To comply with TRID and meet its rigid disclosure specifications, the documents must be truly data driven and software based. For example, if all applicable fees for a subsection on page 2 of the Closing Disclosure do not fit in the space provided, the Rule requires (1) borrowing lines from another subsection within the table, (2) borrowing lines from the other table on that page when all subsections in the table are full, and (3) expanding to two pages when both tables are full. To achieve compliance with TRID, you must precisely follow those steps in order, without the use of an addendum. Conversely, there are certain pieces of information (e.g., property address, borrower and seller data, etc.) that must render on an addendum if they don’t fit in the space provided.

The only way to satisfy these disclosure requirements is with a solution that evaluates data and dynamically assembles tables, sub-sections within tables, and pages based on the transaction. You can no longer rely on documents, forms, or templates to assemble and disclose information or choose when to use an addendum and when to dynamically assemble a table. Instead, appropriate software must be implemented to maintain compliance with the Rule.

Beware existing disclosure requirements

When the CFPB set to work integrating the overlapping TILA and RESPA regulatory frameworks, many disclosure requirements were successfully consolidated under the Rule. However, certain disclosure requirements managed to fall through the cracks. To ensure existing regulatory requirements are satisfied after August 1, 2015, you should do your own assessment of which disclosures are new, which disclosures no longer apply, and review the regulation for any gaps.

For example, creditors today typically disclose hazard insurance premiums and the term on the TIL to avoid having those amounts included in the finance charge under Regulation Z. TRID eliminated the TIL for closed-end mortgage transactions, but it did not provide a new location to disclose hazard insurance information or indicate how those amounts can be excluded from the finance charge after the Rule is in effect.

Until this and other regulatory inconsistencies are formally addressed, the industry is forced to make “good faith efforts to comply” under the existing framework. By being fully aware of regulatory disclosure requirements and knowing how you plan to address them, you can feel confident that your “good faith efforts to comply” will not go unnoticed.

Matching the Model Forms is not enough

Although it’s true that the TRID documents need to follow the Model Forms, the disclosure requirements are too dynamic to be reflected in the limited number of examples that have been provided by the CFPB. The reality is that thousands of disclosure variations must be assembled to comply with the Rule, and many in the industry have requested that the CFPB provide more samples. At this point, that appears unlikely to happen. The Model Forms also include mistakes (feel free to contact me for a list).

The only way to ensure compliance with TRID disclosure requirements, therefore, is to gain a thorough understanding of what the Rule requires. Choosing to rely solely on the Model Forms as templates could lead to some very stressful compliance examinations down the line.

Bon Voyage

My journey into the weeds of TRID turned up quite a few headaches that could easily catch lenders by surprise if they only focus on the big picture features of the rules in preparation of the August 1, 2015 deadline. The examples provided only scratch the surface and failure to comply with the Rule represents unprecedented risk to the industry. It is imperative that you take the proper precautions to prepare yourself not only for the big changes, but also for the less visible details that lurk deep in the weeds.

About The Author

[author_bio]

Joel Haitz is an attorney and product specialist with Compliance Systems, Inc. (CSi). Joel is focused on helping financial institutions navigate the complexities of new financial regulations and consumer-focused regulatory oversight. CSi is a highly respected provider of best-in-class financial transaction technology and expertise. You can reach Joel at jhaitz@compliancesystems.com or visit CSi at www.compliancesystems.com