Lenders all over the country are preparing for the implementation of TRID this week. While compliance with the new disclosure requirements is important, you also need to be ready to deliver electronic evidence of your compliance in the event that the Consumer Finance Protection Bureau visits your offices. Fines for noncompliance could be hefty, and missing evidence might leave the impression that your firm has not complied at all. Make sure you’re set to hit the ground running in early October when it’s time for TRID to be implemented.
Learning from Past Mistakes
When there was last a major overhaul for RESPA in 2010, everyone worked hard to create a GFE/TIL calculator, but no one was willing to stand behind what they created by providing an accuracy warranty. Flash forward to now and it is not surprising that those in the mortgage industry have hesitations about the systems they are currently creating to comply with TRID implementation that is just a few short weeks away.
It looks like so far many of the same crowd are working on creating “Closing Collaboration Portals” so that fee data can easily be exchanged online before closing happens. The overall goal, of course, is to provide more accurate disclosures. What is not yet clear is who will offering the solution that helps with a compliant and complete process that also protects the lender against compliance risks or legal issues into the future.
Read on to look at some of the critical milestones that lenders must now pay attention to in their final checklist of preparation for TRID implementation.
The Application Process
- Establishment of intent to proceed
- Initial disclosure package being provided within three days
- Issuance of any re-disclosures as a result of changed circumstances
Before Closing
- Final disclosures released within three-day period
- Proof of delivery receipt
Electronic Evidence Supporting Compliance
- Date and time stamp filed for all communications with consumers
- RESPA reconciliation for tolerance verification purposes
- Keeping records on file for three years for LE and five years for CD
In addition, it is worth spending some time reviewing the following information:
- Technology vender discussions: Make sure your vendors are on board and clear about the role they play in this new compliance.
- Training: Vendors and other stakeholders should be provided with training about how your own systems will work. Since most of your staff will in some way or another be involved in TRID implementation, set up an in-house training as well.
- Fine awareness: Noncompliance, as mentioned above, could end up costing you. Make sure you know the penalties for noncompliance and how those could affect your office.
- Testing: In the weeks leading up to the deadline, it is a good opportunity to test and test again as you work out the final kinks for compliance. Look for errors and correct them early to save you time and headaches in the future.
Be prepared for this upcoming changing by briefing all of your staff and discussing systems in your workplace to meet this need. Following the steps above will help you be compliant with TRID implementation.
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