Mortgage Compliance

To Close or Not To Close – by TRID

Shakespeare TRID
0 0
Read Time:1 Minute, 57 Second

Shakespeare TRIDAs a result of the upcoming TRID changes, and resultant lender liability, word on the street is that many large banks are considering handling the closings of their mortgage loans in house. Although most banks now handle equity line closings in-house, it’s not the same as doing a purchase transaction with a seller, buyer and Realtor involved. There are quite a few more moving parts. Are they prepared?

Regardless, in light of the new total liability of the lender for ensuring the timely delivery of the new Closing Discourse and the accuracy of all information, many big banks believe it is in their best interest to take on the closing of the loan as well.

By doing so, they can be sure that things are handled correctly at the closing and be in a position to make better decisions on adjustments at the table with more control over the entire process. They can also make corrections and issue new Closing Disclosures on line, in real-time, when minor changes take place at the table. This should result in more accuracy, fewer delays and better customer service.

What effects will this have on a bank’s competitive advantage over a lender not doing their own closings? Will the consumers feel more confident having everything being done by one single entity? What about the big banks now doing correspondent lending?  How will they perform the closings for all their correspondents?  Is this “one stop shopping” better for the borrower?

These are some very important things to think about as the TRID changes draw near:

  • How do you plan to issue your Closing Disclosures and handle your closings?
  • If via the existing structure of the closing agent process, how will you coordinate the information with the various agents involved?
  • Do you have systems in place to gather everything needed to issue an accurate Closing Disclosure on time?
  • Do you have a pre-closing audit function in place to ensure everything is done correctly and timely, and that all fees are disclosed correctly?

How will you handle changes at the table?

There are just so many moving parts.

To close, or not to close; that is the question. Your answer will go a long way toward determining your success or becoming “much ado about nothing.”

Is it time for a change?

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.
Tagged
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.
View all posts by Michael Vitali →