Today comes word that the House Financial Services Committee is expected to take up H.R. 3192 on July 28, 2015 which would provide a temporary safe harbor from enforcement of the TILA-RESPA Integrated Disclosure Rule to February 1, 2016 –“as long as a good faith effort is made to comply with the rule”.
Introduced by Rep. French Hill, R-Ark, this bill would be a welcome relief to various trade groups in limiting litigation exposure to lenders and settlement providers during the weeks & months immediately following October 3, 2015. However, if enacted, the focus will be on what is considered to be a “good faith effort”?
In Mike Vitali’s June 25th Blog Post – he lists the six “T”s of TRID preparation. I am again sharing these with our Blog Post Readers to assist in your Firm’s TRID implementation plans:
- Technology: electronic communications, with doc preparation, delivery & signing
- Timing: having systems, processes & people prepared to ensure disclosures are provided timely & accurately to avoid loss & delays
- Tracking: Systems to monitor activity throughout the process
- Training: ensure all employees are aware of, and perform, their duties as required
- Teamwork: everyone communicating & working together to serve the consumer
- Testing: ongoing pre and post-closing auditing to identify defects & determine where improvement is needed
Stay tuned to the LoanLogics Blog Posts for more TRID-related information in the coming weeks.
Since Mike Vitali is currently on a well-deserved vacation, I hope that his only TRID-related activities include: Tequila, Rum, Ice and Dancing!