Compliance Updates

May: Weekly Compliance Updates

IDS TRID Implementation: Escrows

May 29, 2015

IDS is implementing changes to its Escrows page that will affect workflow and appearance. For IDS Customers who do not enter the idsDoc System to make any manual changes there will not appear to be a difference; however, for those who are accustomed to the current look-and-feel, IDS is providing the following video and documentation to help IDS Customers familiarize themselves with the changes which are related to both non-TRID and TRID related loan transactions.

You may access this tutorial by logging in to idsdoc, clicking on the "Resources" tab, hovering over "Compliance" and clicking on "Compliance Resources".

IDS TRID Implementation: Fee Line Enhancements

May 22, 2015

Based on Feedback from IDS Customers, IDS made a few enhancements to the way the new Fees section of the idsDoc System appears and functions.

The appearance enhancements utilize space that existed on each collapsed fee line to show a breakdown of the fees similar to the way this information appears on the CD. We will compare section A. of the CD with the updated fees page on the idsDoc Website.

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IDS TRID Implementation: Lock Fees in Bulk

May 15, 2015

IDS added a new fee-related feature to the last software release related to TRID. This new feature was added to facilitate administrative controls over the fees. IDS was asked a few times over the last few months if there was a way to “lock” all the fee fields so that processors would be forced to make changes to fee data entry in the LOS—which acts as a system of record. IDS has added the ability for administrators to “lock” or “unlock” fees in a bulk process via Settings and IDS has made this feature available to both TRID and non-TRID loan files.

TRID Implementation: Fees

May 8, 2015

As a part of the IDS Implementation Strategy, IDS released major updates to the Fees page of its proprietary idsDoc System.

IDS is very excited about the added functionality and versatility that this change brings to generating compliant documents via the idsDoc System. For example, the highlighted section above shows that a single fee may be broken down into different “PAID BY” amounts and whether each amount is APR affecting. This feature brings the idsDoc System into conformity with the way the standard MISMO file handles fee breakdowns.

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TRID Hot Topic Series: Analysis of Who Needs to Receive a Copy of the LE/CD

May 1, 2015

1. When one of the joint borrowers agrees to the E-Consent, has the disclosure been “received”?

a. This depends on whether the disclosure being provided is for the LE or the CD, whether the joint borrowers are both primary obligors, and whether the transaction is rescindable or not, e.g.:

i. LE

1. For any type of transaction, e.g., purchase or refinance, only one of the primary borrowers will need to receive a copy of the LE to satisfy the rule.

ii. CD

1. For a rescindable transaction, e.g., a refinance, all consumers with a right to rescind, including title-only borrowers, must “receive” a copy of the CD to meet the rule.

2. For a non-rescindable transaction, e.g., a purchase, only one of the primary borrowers will need to have received a copy of the CD to satisfy the rule.

iii. IDS Implementation

1. In the idsDoc System receipt happens the moment the consumer accepts the eConsent agreement after logging into the IDS E-Sign portal.

2. The current plan is to add a column to the fulfillment report to designate this moment as “Receipt,” so that IDS clients will have a clear demarcation to show investors and auditors compliance with the rule.

3. IDS is also planning on having the “Date Issued” field automatically update in the idsDoc System based upon the date that an LE or CD is actually sent to fulfillment, e.g., In a CFPB call, the CFPB gave unofficial verbal guidance stating that if a disclosure sat in E-Sign for two days, but then was physically postal mailed on the third day, the CFPB would like it if the “date issued” field updated to represent the later date when the disclosure is postal mailed.

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