The changes TRID brought to the industry, as we all know, was transformational, good or bad. From cradle to grave, we all had to make significant changes to processes and systems. Change management was put to the test with these changes.
How successful has your organization been in implementing TRID? What about continued compliance? Has your compliance management system continued to stand strong? Based on Federal Reserve System examiners, as noted in the first issue of the 2019 Consumer Compliance Outlook, common violations were noted. While you may have a few examinations under your belt for TRID requirements, it never hurts to review what regulators are finding that are important enough for them to document and communicate.
Make sure that general information on the Loan Estimate and Closing Disclosure is complete. Regulators look at this information because it’s important for borrowers to have the information at hand in the event that they have questions down the road. Errors or missing fields included:
Loan identification number Settlement agent File number Another important area is to ensure that closing costs and fees are clearly disclosed to borrowers. Fields in the Closing Cost Details table on the Loan Estimate and Closing Disclosure were found to be missing, such as disclosing the number of months for homeowner’s insurance to be paid, the person receiving payment for closing cost services, and funds disbursement for taxes to government entities.
It’s self-explanatory the need to have accurate calculations. It was also noted that violations were found on the Loan Estimate and Closing Disclosure regarding the Calculating Cash to Close table. Violations were observed concerning the omission of required contact information on the Closing Disclosure, page 5, for the lender, mortgage broker, consumer’s real estate broker, etc.
Regulators also noted that strong compliance management systems have certain elements in place that lend to the success of TRID compliance. Specially noted were the following:
Vendor management , Strong communication, Training and effective ,procedures, Secondary reviews , It’s no surprise that your focus is on preparing for the new URLA implementation. Also keep a close eye on TRID compliance.
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Around the Industry:
Recently, the FRB, FDIC, and OCC issued a joint press release that announced the availability of the 2019 list of distressed or underserved nonmetropolitan middle-income geographies where revitalization or stabilization activities are eligible to receive CRA consideration under the community development definition. The historical list of these geographies is available on the FFIEC’s Distressed and Underserved Tracts page.
How does your organization measure up to social media compliance? Check out this article from our June issue on guaranteed tips!