ARE YOU LOOKING? – TRID By James Atkinson
Without exception the major assets in our lives require looking at from time to time. With investments, you need to periodically change the investment direction. On your home it pays to crawl under and go up in the attic periodically to examine the infrastructure. With your automobile, a good “once over” at the service shop is always in order.
In our financial institutions, TRID applicable loans need a “look-over” as well. In a regulatory exam, if your institution has not already been examined for TRID, you can bet a detailed review is on the radar.
Among the many key points to consider are the following:
- Does your staff understand TRID applicability? - Individual or covered trust applicant, closed end/primarily consumer purpose, secured by real property (even commercial real property).
- Is Intent To Proceed documented prior to imposing a fee (other than a credit report fee)?
- How about the initial Loan Estimate (LE)?
- 3 day, 7 day waiting period
- LE redisclosure (as applicable) – 4 days prior to consummation, 7 if mailed
- Projected payments/total of payments accuracy
- All fees on LE in agreement with closing Disclosure (CD) terminology
- How about the CD?
- 3 days prior to consummation, 6 if mailed
- Seller paid fees on P. 2 of borrower’s CD
This “look-over” is a necessity whether you are talking In House TRID or Secondary Market TRID (as regulations hold you responsible for third party vendor due diligence).
So grab yourself a good vendor checklist and give those TRID originations a look. You’ll be glad you took care of it before the examiners arrive.