BankNewswatch

Most Common TRID Issues

Friday, December 16th, 2022 10:00 am - 12:00 pm CT

A BankWebinars.com Program

Click Here to register for live program $279

Click Here to register for live program and recording $419


Even several years after the TILA-RESPA Integrated Disclosures (TRID) rule has been effective, along with a couple tweaks by the CFPB, compliance has been elusive. The rules can be so detailed and prescriptive that 100% accuracy is near impossible. After a year of light-touch exams, where lenders were expected to demonstrate a “good faith effort to comply,” scrutiny of TRID disclosures has become quite intense. Plus, when you consider the legal liability of inaccurate disclosure of the many fees, identifying the many hot spots of TRID becomes paramount.

In this webinar, we’ll explore those hot spots, gray areas, and frequently-violated provisions. We’ll spend time discussing the timing of the various disclosures (which can get quite complicated), disclosure of fees, and calculating tolerances and potential reimbursement issues. Our goal is to ensure you understand where the TRID rules can create uncertainty and risk, and insulate your institution as much as possible from noncompliance.

Topics

  • Coverage issues – straightforward but still a challenge
  • Application issues – data points, preapprovals, and more
  • The complicated timing rules of TRID: the 3-day LE rule, 7-day LE rule, and the 3-day CD rule. Making sure you count correctly.
  • Problems with disclosure of various fees
  • Providing a revised Loan Estimate – when can you do this? How does it impact tolerance issues?
  • Changed Circumstances – what this does and what it does NOT do
  • Proper calculation of tolerances/variances – what is your baseline?
  • Corrected CDs – timing is everything
  • Redisclosure and reimbursement after closing

Faculty

Carl Pry

Carl Pry is a Certified Regulatory Compliance Manager (CRCM) and Certified Risk Professional (CRP) who is a Managing Director for Treliant Risk Advisors in Washington, DC. Through his working career, as well as through his experience as a banking attorney and officer, he has provided a variety of regulatory compliance and financial performance services to financial institutions and other clients throughout the country.