TRID Update – An extension to the extension!

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My colleague ,Mike Vitali, discussed in his blog post on July 21^st the CFPB’s action to extend the implementation date for TRID from August 1, 2015 to October 3, 2015.

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 25^th 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!

Stay tuned!

About the Author

Gerry Glavey

Gerard (Gerry) Glavey is Senior Vice President / Chief Credit Officer for LoanLogics. Gerry has decades of experience working in residential mortgage credit and compliance and brings insights that few in the industry can match. In his role, he develops new services and provides support for all post close quality control and quality assurance, pre-close quality control, due diligence services, and document processing services. He spent 37 years with the US Department of Housing and Urban Development, where most recently he was the Director, Processing and Underwriting Division for the Home Ownership Center (HOC) in Philadelphia. In this capacity, Mr. Glavey was responsible for the administration of all HUD/FHA Single Family Loan Origination activities, including underwriting, appraisal and endorsement for the 16 state jurisdiction of this HOC.