Happy Birthday, TRID!
It’s hard to believe but the TILA/RESPA Integrated Disclosure Rule is three years old this October! Remember when it was a cute little Reg? No? I must confess, neither do I! From the onset of compliance in October 2015 to the publication of the final rule on July 7, 2017, TRID remains one of the more complex regulations for compliance officers to manage.
Up until now, our regulatory exams have not focused on the very technical aspects of TRID. Examiners have certainly focused on any areas of consumer harm, such as tolerance or restitution issues during their regulatory exams, but the technical completion, timing and changes or revisions have been somewhat overlooked.
That tide is turning…
The FDIC has continued to focus on consumer harm: Do your disclosures match the legal obligation? Were fees disclosed in good faith? Were fees changed due to a qualified change in circumstance?
From the OCC’s perspective, its focus is consumer compliance‐related change management processes, focusing on TRID, RESPA, MLA and HMDA. The OCC is also looking for internal controls, procedures and workflow to ensure disclosures are provided on a timely and accurate basis.
In a nutshell, the training wheels are off TRID and it’s the expectation of these regulatory agencies that we get things right: that every “i” is dotted and every “t” is crossed. This also means you should expect TRID exams to be pickier.
Since the beginning of implementation, TCA® has taken TRID seriously and we continue to adjust our reviews based on regulatory updates and clarification. In fact, during a typical loan review, we look at and validate over 100 data points for TRID alone! Our review includes validation of product and terms, payment calculations and payment streams, index and margin values, validation of any revisions to TRID disclosures, fee placement and tolerance calculations, APR and Finance Charge validation and overall form completion. In other words, we check to see that every “i” is dotted and every “t” is crossed.
If you haven’t performed a more thorough TRID review, do so now before the “hammer falls” during your next regulatory exam. Give us a call! TCA is a Better Way to manage your TRID compliance.