Hop to It!

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Last week there was some rumbling about the possibility of the CFPB extending the start date for the required new TRID rules. Don’t get your hopes up (TRID Rule).

CFPB is now making it quite clear that they have no intentions of extending the August 1^st deadline. The requirements for the new rules and new forms will take effect for loan applications taken as of 8/1/2015. No ifs, ands or buts…or so it seems.

Interestingly, a survey now in progress being done by the STRATMOR Group (STRATMOR PeerViews survey) reports that, to date, of those responding, only 15% have their TRID system updates available for testing. Another 24% say they will be ready for TRID testing sometime in April. That’s less than 40% of the respondents indicating they are at least in the testing phase with only 4 months to go before required implementation.

If you like to join the survey, it’s free and is open to senior mortgage lender executives until April 3rd. Participants will receive a report summarizing the findings in early April. The results will be aggregated so that individual company results are not disclosed to any party, nor will they be displayed in such a way that individual company responses could be determined.

With the required implementation date fast approaching, lenders had better start preparing for the issuance of the required new forms along with the changes in their lending process to ensure compliance. It’s not just putting out some new documents; it’s more about when these disclosures are required, what they contain and how they will affect your operation. Be prepared; don’t blindly go running down a rabbit hole.

How/will you know when you have a loan application? How/who will gather all required information needed for the Closing Disclosure? Do you have systems in place to track changes and issue new disclosures? These are very important questions. Hopefully, you’re addressing these issues, as well as others, to ensure your processes and systems are ready for the changes coming in August.

BTW, if you’re a Broker, have you communicated with your lending partners on how the new Loan Estimate will be completed and what fees will be disclosed? Remember this disclosure must be issued in the name of the Lender, not the Broker. If you do not know the lender you’ll use, then that information must be left blank on the form. However, any lender taking the loan is required to abide by the fees you disclose. They cannot change them after registration.

Better hop like a bunny and get ready for TRID.

About the Author

Michael Vitali

Michael L. Vitali – Independent Consultant to the Mortgage Industry Mike Vitali is an independent consultant to the mortgage industry on matters concerning compliance and mortgage lending. He most recently served as the Senior Vice President and Chief Compliance Officer for LoanLogics, monitoring regulatory developments and their practical implications for the mortgage lending industry. His duties included research, interpretation, and analysis of existing and proposed legislation related to the industry in support of recommendations for policy and/or procedure changes to maintain continued quality and compliance with all applicable laws, rules and regulations, investor requirements, and standard mortgage practices. In his more than 40 years in the mortgage industry, in senior level management, he has gained experience in all areas of mortgage lending, risk management, and compliance. Mike is a past President of the MBA of Greater Philadelphia, is a charter member and was the second Chairman of the MBA of Pennsylvania, and a past board member and Legislative Chair of both associations. He is a recipient of the 1998 Mortgage Banker of the Year Award from the MBA of Greater Philadelphia, and the 2003 Chairman's Award from the MBA of PA, and currently serves on several compliance related task forces for MBA.