Mortgage Compliance

Are You Ready For Some “TRIDball”?

Trid-Football
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Trid-FootballThe NFL football season finally got into full swing on Sunday with a slate of games nationwide. There was drama, intrigue, excitement and fun for all (except if your team lost). For the most part, it was a typical fall Sunday afternoon (although it’s not quite Fall, yet). There were great games, upsets, controversy and big plays, with one major change; the PAT, point after touchdown.

The PAT is commonly referred to as the “extra point”, as up until this season it was considered an automatic add on after a touchdown. Very rarely was the kick to gain the additional 1 point missed. It was nearly automatic.

However, to spice things up, and add some uncertainty to the betting lines, the league decided to move the starting point for this PAT from the 2 yard line back to the 15, increasing the attempt from about 20 yards up to now 33 yards. Not so automatic anymore, as we saw on Sunday. A few of these PAT’s were missed.

As an alternative, a team may choose to go for 2 points, instead of 1, by running a play from the 2 yard line instead of kicking from the 15. This option is not as automatic as opposing teams may better defend an action play versus trying to block a PAT kick.

Another change is that the defense can now score 2 points by returning a blocked kick or botched 2 point attempt. This can drastically change the potential outcome of a game, the point spread, and how teams decide to approach the PAT.

This a little more than a mere change in the rules, or extension of the distance to kick a PAT,  it is something that could change how the game is played and a coaches approach to the PAT depending on game circumstances and conditions when touchdowns are scored. The game has changed…

Like the PAT rule change, the TRID rules present a challenge to a lender and a cultural change in how they need to approach their business. Lenders will continue to issue estimates of their charges and closing costs, along with specific loan details when they take a new application. They will manage and update this information when changes occur so the consumer is well aware of what is happening with their loan.

However, with the change they must ensure the consumer receives a final accounting of what is to take place at the closing at least 3 business days prior to the loan consummation. This is something new that will alter how lenders should approach the game and what they need to do when it comes to crunch time; the loan closing.

How this it handled will determine a lender’s success or failure. Lenders must manage the loan process from beginning to end to ensure that the loan is properly disclosed upfront, identify changes during the process, and issue revised disclosures to update fees and information and the new Closing Disclosure in a timely manner. Otherwise, they will be penalized.

No more can a lender wait until the last minute to make a decision on what to charge and how to notify a consumer of a change. The closing papers cannot be provided to the consumer at the last minute or at the closing table for a quick review and closing. Consumers must be provided all information about their closing well in advance and lenders must have the systems and processes to ensure this gets done correctly and on time. There is no second chance.

Are you prepared for the TRID rule changes? Do you have a game plan to ensure compliance and timing? Can you avoid last minute delays and handle changes at closing? Will you earn and retain your PAT; profits after TRID?

Are you ready for some TRIDball? It’s coming soon to a closing near you.

The game has changed; play different!

Michael Vitali

About the Author

Michael Vitali

Michael L. Vitali – Independent Consultant to the Mortgage Industry Mike Vitali is an independent consultant to the mortgage industry on matters concerning compliance and mortgage lending. He most recently served as the Senior Vice President and Chief Compliance Officer for LoanLogics, monitoring regulatory developments and their practical implications for the mortgage lending industry. His duties included research, interpretation, and analysis of existing and proposed legislation related to the industry in support of recommendations for policy and/or procedure changes to maintain continued quality and compliance with all applicable laws, rules and regulations, investor requirements, and standard mortgage practices. In his more than 40 years in the mortgage industry, in senior level management, he has gained experience in all areas of mortgage lending, risk management, and compliance. Mike is a past President of the MBA of Greater Philadelphia, is a charter member and was the second Chairman of the MBA of Pennsylvania, and a past board member and Legislative Chair of both associations. He is a recipient of the 1998 Mortgage Banker of the Year Award from the MBA of Greater Philadelphia, and the 2003 Chairman's Award from the MBA of PA, and currently serves on several compliance related task forces for MBA.
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Michael Vitali

About Michael Vitali

Michael L. Vitali – Independent Consultant to the Mortgage Industry Mike Vitali is an independent consultant to the mortgage industry on matters concerning compliance and mortgage lending. He most recently served as the Senior Vice President and Chief Compliance Officer for LoanLogics, monitoring regulatory developments and their practical implications for the mortgage lending industry. His duties included research, interpretation, and analysis of existing and proposed legislation related to the industry in support of recommendations for policy and/or procedure changes to maintain continued quality and compliance with all applicable laws, rules and regulations, investor requirements, and standard mortgage practices. In his more than 40 years in the mortgage industry, in senior level management, he has gained experience in all areas of mortgage lending, risk management, and compliance. Mike is a past President of the MBA of Greater Philadelphia, is a charter member and was the second Chairman of the MBA of Pennsylvania, and a past board member and Legislative Chair of both associations. He is a recipient of the 1998 Mortgage Banker of the Year Award from the MBA of Greater Philadelphia, and the 2003 Chairman's Award from the MBA of PA, and currently serves on several compliance related task forces for MBA.
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