August 1 is less than three months away. I hope you understand the significance of this date. If you don’t, you may have been living under a rock for a while. The Truth in Lending Act/Real Estate Settlement Procedures Act integrated disclosure (TRID) goes into effect on that day.
TRID is the CFPB’s latest attempt to protect consumers from themselves. According to its small entity compliance guide, the CFPB says “The TILA-RESPA rule consolidates four existing disclosures required under TILA and RESPA for closed-end credit transactions secured by real property into two forms: a Loan Estimate that must be delivered or placed in the mail no later than the third business day after receiving the consumer’s application, and a Closing Disclosure that must be provided to the consumer at least three business days prior to consummation.”
I’ve heard some who think this is a disclosure regulation. And it primarily is. It changes the TILA and RESPA forms and changes the closing process. Because of this, some are relying primarily on their software or forms provider to make sure they are in compliance.
That’s a big mistake. Many believe this will be a bigger deal than Qualified Mortgage rule from January 2014.
TRID is so much more than a disclosure regulation. It’s a game changer, and if you aren’t prepared, your ability to be memberlicious will be seriously compromised.
The technology and forms are an important part of the process. You need to be sure your technology and forms provider can produce the forms and that the right data is mapped to the right box. And you need to make sure the technology allows you to track all the key dates that are so important within TRID.
Get this right and it means you are equipped to handle TRID, but what about everyone else?
Click over to the Mortgages Are Memberlicious blog to read about how to train staff on the new regulation, how to implement the new requirements into the credit union's operational workflow, how to prepare the closing statement, how to communicate the impacts of TRID to the local real estate community, how to communicate TRID to borrowers, and more.
To follow Morgages Are Memberlicious, email Mislansky directly at tmislansky@myCUmortgage.com.