Uncategorized

Time Marches On

Beat The Clock 1958 CFPB TRID
0 0
Read Time:2 Minute, 15 Second

Beat The Clock 1958 CFPB TRIDShockingly, a recent survey, done by Capsilon Corp, a company providing cloud-based document sharing, imaging and collaboration for business, reveals that a large number of mortgage lenders may not be fully prepared to implement the required TRID changes (Survey).

Time is running out for these lenders.To date, the CFPB has made it clear that they do not intend to grant any extensions. The clock is ticking…

Recently, there have some rumblings in Congress about a possible move to have CFPB extend the TRID implementation date to sometime past 8/1/2015. Many lenders, along with technology and document providers are hoping for a reprieve, but to date – nothing, nada, crickets. Tick, tick, tick…

  • Are you ready for TRID? Not just with the technical aspects needed to complete and issue the new disclosures, but with the changes to your entire origination process to meet the new requirements?
  • Can you identify when you have the 6 items which determine a loan application? Can you ensure disclosures are sent and received timely?
  • How will you obtain/gather the information from all related parties to prepare and ensure a timely Closing Disclosure?

You might want to consider a pre-closing audit of all loans coming up for closing, at least initially in the first few months after the changes become effective. This investment in quality and accuracy will pay big dividends in avoiding delays and losses.

Did you know:  on loans the FHA insures, that have FHA case number assignments as of June 15, 2015, the FHA will be requiring pre-closing audits? Everyone wants to reduce defects and increase loan quality. It’s about time.

If you need a little help you can go to www.loanlogics.com/trid and view some reference materials on the new rules and related disclosures. This may help in readying you, and your staff, for what’s about to come, and provide a quick reference guide to help in answering some of their questions. Use it with my (and LoanLogics) compliments.

If you are not yet ready, I strongly suggest you get moving. Don’t bank on an extension. Although history may have shown that in these cases extensions do get granted, such history is not based on the actions of the CFPB. It is not prudent to wait. If you believe it is, maybe you should head for Vegas or AC and put it all on “black” (or “red”; your call). Odds of the extension are about the same, maybe a little better at the casino.

The rules have changed; time to play different! Will you beat the clock?

(Can you name the early host of Beat the Clock shown in the picture above?)

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 →