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New TRID Amendments:  The Four Things You Need to Know

Posted by Andy Crisenbery on Aug 3, 2016 7:17:14 PM


In April, the Consumer Financial Protection Bureau (CFPB) promised amendments to TRID – the Truth in Lending Act (TILA), Real Estate Settlement Procedures Act (RESPA) Integrated Disclosures. After the official roll out of the disclosures in October, the CFPB convened a series of webinars to provide guidance on implementation questions. Then this spring, CFPB Director Richard Cordray announced plans to codify guidance and amend certain provisions in July with a new proposed rule.

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Topics: CFPB Regulations, TRID

Post-TRID: Are We There Yet?

Posted by Alec Cheung on Jul 8, 2016 3:00:24 PM


It’s been more than six months since the mortgage industry rolled out the new Truth in Lending Act (TILA), Real Estate Settlement Procedures Act (RESPA) Integrated Disclosure (TRID) rule, and data is starting to suggest that the industry might be getting the hang of things. While the initial implementation period is behind most of us, there is still work ahead to streamline compliance in support of the disclosure requirements, work out operational kinks between vendor and lender integrations and anticipate additional changes as the Consumer Financial Protection Bureau (CFPB) as they continue to clarify industry questions.

According to the National Association of Realtors’ March 2016 REALTORS® Confidence Index Survey Report, the average closing time for mortgage loans fell to 41 days, down from 43 days from previous months and representing the shortest duration since October 2015. The metric has come down nearly a week in average closing time since TRID implementation. In November, December and January, immediately after the new disclosures rolled out, average days to close jumped up lingering around 46 days.

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Topics: CFPB Regulations, TRID

Industry Hopeful for Second Chance at TRID

Posted by Alec Cheung on Jun 23, 2016 5:06:24 PM


The Consumer Financial Protection Bureau (CFPB) recently published its Spring 2016 rulemaking agenda.  One of the current initiatives on the agenda is the forthcoming release a Notice of Proposed Rulemaking (NPRM) to provide additional guidance and clarification pertaining to the Truth in Lending Act (TILA), Real Estate Settlement and Procedures Act (RESPA) Integrated Disclosures (TRID) rule, also referred to as the Know Before You Owe (KBYO) mortgage rule.  The NPRM is slated for release mid-July and will likely lead to an amendment to the TRID rule.  Industry stakeholders look forward to the long awaited rule clarification and guidance that was absent at time of implementation.

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Topics: CFPB Regulations, TRID, NPRM

Electronic document investments are paying off. Are you ready to cash in?

Posted by Alec Cheung on May 6, 2016 11:59:09 AM


Financial service providers that have invested in technology solutions are starting to see big returns on their investments. Regulators have made leaps this year to embrace electronic documentation and data collection, as well as other innovative solutions. First, the Consumer Financial Protection Bureau (CFPB) announced February a new policy to provide no-action letters to reduce regulatory uncertainty around the use of innovative products and services in the consumer financial space. Then, in March, the Office of the Comptroller of the Currency (OCC) published a white paper on how the agency can support responsible innovation in the federal banking system through the burgeoning financial technology, or ‘fintech,’ sector.  The Federal Reserve is the latest to follow suit with a recent announcement that it will permit off-site examinations to certain financial institutions relying on electronic document and data submission.

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Topics: Fintech, Financial Technology, Federal Reserve Off-Site Examination

CFPB Welcomes Innovative Vendors

Posted by Alec Cheung on Apr 21, 2016 4:49:41 PM


In the six months since the TRID rules went into effect, most of the industry has been heads down working to ensure compliance and adapt their internal work processes. Most lenders and vendors have had to focus all available resources on accommodating the new requirements. While to a great extent the Know Before You Owe initiative has succeeded in improving things for consumers, by necessity, much of the technology development and innovation has been oriented towards helping lenders and settlement service providers meet their obligations. Much work still remains to be done on that front but now the consumer experience is getting more attention by the lenders, technology vendors and the CFPB.

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Topics: CFPB Regulations, No Action Letter CFPB, Consumer Experience

The Most Surprising Thing I Learned At MBA Tech 2016

Posted by Alec Cheung on Apr 14, 2016 6:45:09 PM

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Have you ever gone to a movie expecting to see one movie only to find out a completely different one was playing? I had a bit of this experience at the MBA Technology in Mortgage show in L.A. last week. At the show, I fully expected the main topic of conversation among our lender customers and prospects to be the challenges they were facing operationalizing Know Before You Owe (KBYO). My expectation was based on what I saw as the “previews” leading up to the show. Media coverage and anecdotal stories centered around the added cost and processing time required to comply with the new rules. In particular, I heard about problems obtaining accurate fees for the Loan Estimate and issues collaborating with settlement agents when preparing Closing Disclosures. In the early stages of the new KBYO reality, we knew lenders were relying on some level of manual processing in order to get by. Even as a temporary measure, this had proven to be an expensive and error-prone way to support KBYO. We fully expected the buzz to be about how to rectify these pressing challenges. To our surprise, the topic of improving consumer experience actually trended higher.

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Topics: TRID, MBA Tech, Consumer Experience, KBYO

5 Survival Tips for Living in the CFPB Spotlight

Posted by Alec Cheung on Apr 7, 2016 3:01:57 PM


The Consumer Financial Protection Bureau (CFPB) recently captured the attention of nearly everyone in the consumer financial services industry when it published its policy priorities for the next two years. For industry stakeholders, the watchdog’s agenda plays an undeniable role in shaping compliance policies, investment and business planning. And of course, it should come as no surprise to anyone who has followed the mortgage industry in the past five years, the mortgage market made the cut as one of nine top priority goals. With the CFPB signaling no intention to let up on regulation, oversight and enforcement of the mortgage industry, it raises the question of just how mortgage lenders, servicers and other third-party providers can manage years on end in the glare of the agency’s spotlight.

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Topics: cfpb policy priorities

TRID’s Greatest Challenge: Estimating fees accurately AND quickly

Posted by Alec Cheung on Apr 1, 2016 1:55:07 PM


How can lenders quickly get accurate fees for the Loan Estimates they produce? This is one of the more significant challenges lenders face under the new TRID rule. Due to tighter restrictions on what fees can change and by how much, lenders need accurate fees when they create the Loan Estimate. And with the stricter timelines for disclosing fees to the consumer, they need the fee data very early in the loan process. Lenders who can’t meet this challenge may find themselves having to choose between a delayed closing or having to absorb disallowed fee changes. 

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Topics: Loan Estimate Fee, TRID Challenge

New HMDA Rule Keeps Mortgage Data in the Spotlight

Posted by Dewey Kelly on Mar 8, 2016 4:22:44 PM


Having just kicked off 2016, 2018 feels far into the future. However, if the recent Truth in Lending Act (TILA), Real Estate Settlement Procedures Act (RESPA) Integrated Disclosures (TRID) implementation was any indication of industry timelines, it's not too early to start evaluating the Home Mortgage Disclosure Act (HMDA) final rule and the impact it will have on current data collection and reporting processes. Concerns are surfacing in several areas as the mortgage industry begins to assess the impact of new data requirements.  The Consumer Financial Protection Bureau (CFPB), working to address early comments, issued a request for information (RFI) and is already working with industry stakeholders to smooth the way for necessary changes that will make the market work better for consumers.

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Topics: CFPB Regulations, MISMO, Data Standards, HMDA Implementation

Are we over the TRID hump yet?

Posted by Alec Cheung on Feb 10, 2016 9:12:44 PM



Now that we're a solid four+ months into TRID, the transition challenges faced by the industry of implementing the new mortgage disclosures are evident. While very early assessments suggested that the impact of TRID implementation was fairly minimal, even going so far as to compare it to ‘Y2K,' it's now clear how much of a challenge this has been for the industry. 

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Topics: CFPB Regulations, Integrated Disclosures, TRID