Compliance Updates

October: Weekly Compliance Updates

TRID Hot Topic Series: Creating and Delivering the Written List of Providers

October 17th, 2014

The Written List of Providers is an interesting piece of the TRID puzzle. It’s the one separate document (§ 1026.19(e)(1)(vi)(C)) from the actual LE and CD mandated by the rule that has the same look and feel, by design, as the LE and CD. As one presenter from the MBA conference put it, “if the CFPB went to the trouble of creating a model form for the service provider list that looks like the LE and CD, then you had better use it (paraphrasing).”

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TRID Hot Topic Series: Managing Online Application Systems

October 10th, 2014

There has been some discussion throughout industry regarding management of Online Application Systems. The discussion revolves around the stricter definition of application and how companies will gather the information they need (or would really like to know) before triggering the requirement to provide a Loan Estimate. Just to recap, the stricter definition of application brought on by the new rule simply drops a seventh “catch-all” option that allowed lenders to define their own additional requirement beyond the remaining six items* defined by the rule, which are as follows:

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Did You Know Series: HUD changes FHA prepayments requirement

October 3rd, 2014

IDS recently attended MBA’s Regulatory Compliance Conference 2014, held in Washington, D.C., September 28-30. At the conference a group of panelist presented their list of the Top 20 Issues that will result from implementation of the TILA-RESPA Integrated Disclosures (TRID). Highlighted in green are each of the issues from the list that have been touched on by this blog’s TRID Hot Topic Series, the others will be approached over time:

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TRID Hot Topic Series: MBA’s List of Top 20 Issues

September 26th, 2014

The short answer is “No.” Here’s why: RESPA itself does not go away just because certain transactions are now covered by the TILA-RESPA Integrated Disclosures. Rather than replace RESPA, transactions covered by TRID fulfill RESPA. And as for the GFE and HUD-1, there are certain transactions like reverse mortgages that are not covered by TRID, but are still covered by RESPA. For example, if a mortgage company would like to originate a reverse mortgage, the mortgage company would need to provide a GFE and a HUD1 even if it chooses to use the LE and CD. Page 20 of the CFPB’s Small Entity Compliance Guide provides the following further clarification:

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