MReport September 2015 - Cool Under Pressure

TheMReport — News and strategies for the evolving mortgage marketplace.

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12 | Th e M Rep o RT the pulse Countdown to TRID With time running out until the october 3 effective date, our pros give their advice on how lenders and servicers can make this last month count. T he date is set and the pressure is on—after October 3, 2015 companies will be levied with heavy fines if they are found to be non-compliant with the TILA-RESPA Integrated Disclosure (TRID) rule. Never fear—there is still enough time to dot your i's and cross your t's to ensure you have adequately prepared. To provide you a guideline of where to start, we've picked the brains of some of the best tech providers in the biz. Tim Anderson Director of eServiceS, DocMagic, inc. A basic checklist of the critical items you will need not only ensures compliance, but more importantly delivers the electronic evidence when the CFPB comes knocking on your door asking you to prove you did what you said you did to prevent paying fines that could run up to $1 million dollars a day. So much focus has been on the forms, specifically the CD and the three-day delivery requirement, but implementing a true compliant process requires confirmation and tracking of the following critical milestone events. Application: 1) Intent to proceed 2) Three-day delivery of the initial disclosure package, (not just the LE) 3) Changed circumstances and re- disclosure(s) Pre-closing: 1) Three-day delivery of final closing disclosure (CD) 2) Why just the one form and not all like we do with the initial disclosures? 3) Show receipt of delivery Electronic evidence: 1) RESPA reconciliation to verify tolerance and other compliance checks 2) Date and time stamp audit trail of all consumer communications 3) Record retention requirement of three years on LE and five years on CD Implementing a full electronic (eSign, eDisclosure) process from loan application to closing is the only way to truly be and ensure compliance. There is a reason why the CFPB and now FHFA is standardizing on the MISMO 3.3 data spec and that is because they are moving to support a full automated audit of the data file for compliance and not wade through hundreds of pages of the paper file to verify compliance. Jerry HAlbrook PreSiDent of Black knight origination technologieS, a DiviSion of Black knight financial ServiceS In the few weeks before TRID goes into effect, lenders are most likely reviewing their processes, confirming that necessary training has been completed, testing integrations with third-parties, and following up on outstanding deliverables. If they haven't already done so, they should make sure their contin- gency plans are in place to address unexpected issues that might arise, and that technology and service partners also have adequate contin- gency plans in place. Strong safety nets like contingency plans and resources can make all the difference in the world should something— even something small—not go as planned. From technology and process performance, to the readiness of internal staff members and external partners, this is the time to verify, fine- tune, or remediate as necessary, then verify again.

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