Compliance Updates

January: Weekly Compliance Updates

TRID Hot Topic Series: Pre-application Cost Estimates

January 30, 2015

This topic references a “written estimate of costs or terms” or a “worksheet” often provided by creditors to potential consumers regarding costs associated with a particular loan transaction. Presumptively, these worksheets are used more as a marketing tool than as an actual breakdown of costs associated with a particular person’s potential mortgage on a specific property. The rule provides a place for these pre-application cost estimate worksheets after TRID goes into effect; however, to reduce the consumer’s potential confusion between a worksheet and an LE, the rule requires (1) a conspicuous disclosure at the top of these worksheets and (2) a type of formatting that does not resemble the appearance of the Loan Estimate (LE). The required disclosure must be in a font size that is no smaller than 12-point font and must state:

Your actual rate, payment, and costs could be higher. Get an official Loan Estimate before choosing a loan. (Read More)

TRID Hot Topics Series: Varying Time Period for Correcting Closing Disclosures and Refunding Money Post-Closing

January 23, 2015

“30-30, 60, 60″—these numbers represent the mnemonic that IDS Compliance came up with to help remember the timing requirements for LE/CD-related fixes required post consummation. Tip: if you say “30-30, 60, 60″ fast enough in a discussion with colleagues surrounding today’s topic, you’ll always sound precocious. Here’s a breakdown of “30-30, 60, 60.”

(Read More)

TRID Hot Topic Series: Transitional Period When HUD-1 and Closing Disclosures Will Both Be In Use

January 16, 2015

The TILA-RESPA Integrated Disclosure (TRID) rule is very firm about its implementation date of August 1, 2015. As a part of the implementation date, the rule specifies that lenders are neither allowed to begin using the disclosures early nor allowed to use the new disclosures on loans where the creditor received an application before August 1, 2015. The preamble to the TRID Final Rule states:

(Read More)

IDS TRID Webinar Series: Schedule for TRID Webinars 2 and 3

January 9, 2015

IDS Compliance held its first TRID-related webinar on November 18, 2014, entitled IDS TRID Webinar: Implementation Plan Overview. Slides and a copy of the presentation are available for review on the Compliance Resources page of the IDS Resources website.

IDS Compliance will be holding two more TRID Webinars, which are scheduled as follows:

  • March 17, 2015. IDS TRID Webinar: System Changes
  • June 30, 2015. IDS TRID Webinar: Customer Testing
IDS Marketing will send out invitations to participate a few weeks before each scheduled webinar. Slides and recorded copies of the webinars will be made available on the Compliance Resources page of the IDS Resources website within 24 hours of each programmed webinar. It is anticipated that the June 30, 2015, webinar will serve as a guide for ensuring that IDS Customers are fully prepared to use the idsDoc System to generate the new TILA-RESPA Integrated Disclosures.

TRID Hot Topic Series: Published TRID Implementation Plan Timeline

January 2, 2015

IDS Compliance is republishing its intended TRID Implementation Plan Timeline. The timeline has experienced very minor changes since its inception 03/28/2014. The most commonly asked question from IDS Customers deals with when IDS Customers will be able to begin testing the new disclosures. Please note that there will be limited IDS Customer testing beginning in May and plenary IDS Customer testing in July. IDS’s implementation plan includes doing the following:

(Read More)