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Massive changes to the Truth In Lending/ Real Estate Settlement Procedures Act Integrated Disclosures (TRID) rules are mandatory on October 1, 2018. Every creditor needs to update their loan origination software, TRID policy, procedures and training to implement the changes.
The Consumer Financial Protection Bureau (CFPB) published a final rule to implement the new integrated disclosures (TRID) on November 20, 2013. The final rule was effective on October 3, 2015. The TRID rules and guidance from the CFPB continue to evolve. After much industry confusion and concern regarding elements of the regulation, the CFPB released a proposal to update the TRID regulation in July 2016. The final TRID Amendments, consisting of 556 pages, were released on July 7, 2017, with a mandatory compliance date of October 1, 2018.
This three-part webinar recording reviews the 2017 amendments and explains how the massive amendments impact the existing rule, including:
- The general rules contained in §1026.19;
- The content rules and the detailed instructions for completing the loan estimate from §1026.37; and
- The content rules and the detailed instructions for completing the closing disclosure from §1026.38.
The amendments contain a lot of good news, mainly in the form of clarification on issues where details were lacking, such as construction loans. Some of the changes can be implemented at any time. Others provisions cannot be implemented until your loan origination software is updated. Before the dates of these three programs your loan origination software vendor should have distributed the system update for testing and implementation.
Daily TRID management continues to challenge many banks and lenders; this three-part webinar provides a thorough review of the 2017 amendments. Whether you are new to TRID or have been involved since its inception, this review of the 2017 amendments provides the information you need in order to implement the changes.
You’ll receive a detailed 150-page manual that serves as a handbook long after the recordings are viewed.
Upon viewing of the recordings participants will understand:
- Revised coverage and exemption rules;
- Timing of construction loan disclosures;
- Revised rules for written list of providers;
- Clarification of tolerance rules;
- Tolerance requirements for charges paid to an affiliate;
- 2018 revision regarding the regulatory black hole;
- Clarification on when and how to disclose a rate lock;
- Sales price versus estimated property value;
- Clarification of the disclosure of loan term;
- Clarification of the product disclosure;
- Clarification of expiration date;
- Clarification of projected payments;
- Clarification of inspection and handling fees;
- Can/Cannot Shop v Did/Did Not Shop – Tolerance shift;
- Proper Disclosure of lender, seller, and other credits; and
- Construction loan issues
- Accurately disclosing the Calculating Cash to Close table;
- Proper completion of the Comparisons disclosure;
- Guidance on sharing disclosures with various parties involved in the mortgage origination process;
- Proper disclosure of the Escrow Account disclosures;
- When and how to complete the Liability After Foreclosure disclosures;
- New tolerance requirements for the total of payments;
- How to disclose simultaneous subordinate lien loans; and
- More construction loan issues.
This recording is designed for mortgage loan department managers, compliance officers, loan officers, auditors and others with responsibilities for preparing, delivering or auditing the new disclosures.