 Industry Hot Topic: TILA/RESPA Integrated Disclosures (TRID) PART V CFPB Announces Two-Month Delay on TRID Enactment "The CFPB will be issuing a proposed amendment to delay the effective date of the Know Before You Owe rule until Oct. 1, 2015," said CFPB Director Richard Cordray. "We made this decision to correct an administrative error that we just discovered in meeting the requirements under federal law, which would have delayed the effective date of the rule by two weeks. We further believe that the additional time included in the proposed effective date would better accommodate the interests of the many consumers and providers whose families will be busy with the transition to the new school year at that time." Changes In Store for Residential Mortgage Loan Closings
excerpts from article by Mel Tull, VBA General Counsel
Beginning October 1, the borrowing public will experience fundamental changes in the closing process for most residential mortgage loans as lenders implement the new TILA/RESPA integrated disclosure rules (TRID).
TRID replaces the Good Faith Estimate form, the initial TIL, the Appraisal Disclosure and the Servicing Transfer Disclosure with a Loan Estimate form that contains estimated loan closing costs and must be delivered or mailed to the borrower no later than three business days after receipt of a loan application and at least seven business days before closing. TRID also replaces the HUD-1 form and final TIL with a Closing Disclosure form that contains final closing costs and general loan information/terms and must be delivered to the borrower at least three business days prior to closing.
To facilitate timely closings and avoid delays, borrowers, loan originators and real estate brokers should conduct inspections and walk-throughs as early in the process as possible to allow ample time to react to any adverse discoveries.These items, invoices and all other loan related cost information, such as home owners' association dues and special assessments, should be provided to the lender as soon as possible and no later than seven to ten business days prior to closing, to allow ample time for coordination and finalization of the entire document between the lender and the closing agent.
Borrowers, loan originators and real estate agents are encouraged to anticipate delays and take precautions to mitigate the impact of delays as the entire real estate industry adjusts to the new rules, forms and closing procedures Allotting more time between the execution of a purchase contract and the scheduled closing may be advisable (such as 60 days rather than 30 days). Longer interest rate locks may be prudent (again, 60 days may be more appropriate than 30 days). It may be a good idea not to schedule multiple contingent closings close in time given the increased risk that any one of the transactions could be delayed. For example, back-to-back closings where the proceeds of a sale transaction in the morning are used to close on a purchase in the afternoon are risky given that the morning transaction could be delayed three days to deliver a revised Closing Disclosure. Click HERE to read Mel's article in its entirety.
It's Here! Investors Title Insurance Company Announces "TRID--Together We're Prepared" Seminar Series On-Demand
We are pleased to announce that Investors Title Insurance Company "TRID - Together We're Prepared" seminar series is now available through their new on-demand education portal. We encourage you to view each of the three modules for a comprehensive understanding of the new CFPB rules and disclosures. In addition to the video presentations, participants are given access to Investors Title's online TRID resources.
Click HERE for instructions on how you may register your account and view the webinars.
TRID Changes and People Skills by David Lykken
Much has been written about the struggle to get business practices in compliance with TRID. Much has also been written about the technology that can help mortgage organizations become compliant. Little has been written about the importance of strengthening the communication skills of LOs in preparation for TRID. If our people can't communicate the changes to borrowers in a way that instills confidence and puts them at ease, then all of our other changes will have been for naught. As TRID integration becomes a reality, do your people know how to talk about it comfortably and confidently with borrowers? Read more... ______________________________________________________________________________ As you move through the learning curve with these new rules and forms, Virginia Title Center is here to assist you. Please do not hesitate to reach out to our Agency Manager, Bobby Fothergill (1.800.468.5811 or bfothergill@virginiatitlecenter.com). Please reference TRID materials available on the Virginia Title Center website: TRID Training, Reference and Forms Manuals are available for download HERE. Together We're Prepared!
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