Welcome to the Compliance Cohort. We are a group of compliance professionals working to make compliance easier. Our goal is to take complex compliance concepts and put them in simple terms that apply to the real world. We are glad you have found us and look forward to collaborating in the future.
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All in TRID
In this Compliance Clip (video), Adam answers the question of whether construction-only and construction-permanent loans are covered by TRID and Regulation Z. And although the answer is obvious, Adam discusses the specific citations from the regulations and from the CFPB’s Frequently Asked Questions to further explain the answer. A transcript of this video is now available.
In this Compliance Clip (video), Adam discusses the requirements for having a signature line on the LE and CD. While many financial institutions may not have thought about whether this is required or not for some time, it might be a good idea to revisit the rules to ensure things are being done correctly.
In this Compliance Clip (video), Adam goes into a little bit of a deep dive to explain the Total of Payments disclosure on the Closing Disclosure. This a TRID and lending topic, which is especially helpful for lenders or somebody who's responsible for the loan department. A transcript of this video is now available.
In this Compliance, Adam discusses what a lender credit is for purposes of the TRID rule. In particular, Adam specifies items that are considered lender credits and gives examples of payments that not are considered a lender credit. In addition, Adam briefly describes the difference between a specific and a general lender credit. A transcript of this video is now available.
In this Compliance Clip (video), Adam talks about the loan purpose on construction loans and how it is treated on the Loan Estimate and the Closing Disclosure. Construction loans seem to be a challenge especially when it comes to loan purpose but it shouldn't be that difficult. Watch as Adam explains the TRID purpose “waterfall”.
In this Compliance Clip (video), Adam discusses how a creditor discloses lender credits if the creditor provides a credit rebate or reimbursement to offset specific closing costs charged to the consumer. This is a TRID topic.
On 6/18/2021, CFPB Acting Director, Dave Uegio, issued a statement on the impact of the new Juneteenth Holiday on residential mortgage closings. As a background, President Biden signed into law the Juneteenth National Independence Day Act on June 17, 2021, just two days before the actual new holiday of June 19, 2021. As this new holiday is a Federal Holiday, Financial Institutions immediately had concerns regarding implementation of the new Juneteenth Federal Holiday, particularly as it relates to mortgage compliance under Regulation Z and the Truth in Lending Act.
On 5/14/2021, the CFPB published a set of 5 new TRID FAQs on their website. These FAQs relate to housing assistance loans and are the first TRID FAQs to be released in nearly a year. The new TRID FAQs answer the following questions:
In this Compliance Clip (video), Adam discusses the 6 pieces of information required for an application under TRID. He explains a few nuances related to this as well as a few things to watch out for.
In this Compliance Clip (video), Adam answers a questions about disclosing a prepayment penalty on the Loan Estimate (and Closing Disclosure) when the note allows for a fee to recoup some costs if the loan is paid off with the first 36 months after consummation. While this shouldn’t be a day-to-day TRID question for any lender, this is something that should be looked at as this could be a systemic violation of Regulation Z if not disclosed properly. Click the link to watch this 5 minute video.
