MReport September 2015 - Cool Under Pressure

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Th e M Rep o RT | 13 the pulse Anthony Box VP of SaleS, NetDirector As the deadline to comply with the upcoming TRID requirements quickly approaches, lenders and loan origination industry participants need to be proactive and show that they are making a good faith effort to comply. By ensuring their ability to communicate and collaborate with other service providers efficiently, they will be able to comply with the TRID requirements more easily and with fewer resources. With a cloud-based data exchange, lenders and servicers can exchange data and documents with their trading partners in a bi-directional manner and in real-time. Choose a company that maps the MISMO 3.3 logical data dictionary within their Web application so it can be mapped to and therefore communicate with any vendor, service provider, or other trading partner you need to transact with. Even if your solution has not gone as planned, or you simply find yourself behind in the system integration plans, there is still time to connect with your trading partners by utilizing a cloud-based data exchange to meet the deadline. Phil MccAll coo, arMco Thanks to TRID, there have been critical changes within the LOS's, policies and procedures, and the overall manufacturing process. However, my question is, have you proactively included your quality control team in these changes? The TRID regulations will require new processes for many of your origination personnel. The implementation of revised procedures will be prevalent throughout the manufacturing process; from the initial Loan Estimate through the acceptable Changes in Circumstances to your final Loan Disclosure. Your manufacturing process has most definitely been altered, but have you sufficiently revised your quality control processes to account for these alterations? With every change to accommodate the new TRID regulations there are reciprocating changes to your quality control process and procedures, checklist questionnaires, and validation process. As an organization, have you included your quality control team in the manufacturing process changes that are being implemented to account for the new TRID regulations? If you are not 100 percent positive of this answer, now is the time to confirm that you have adequately prepared your quality control team to properly monitor the changes within your organization. MArk McElroy ceo aND PreSiDeNt, PaVaSo As the TRID deadline approaches, lenders must ensure that they have the tools and procedures in place to address the following three concerns: 1) Securely deliver the LE and CD electronically to meet the three-day rule and beat competitors post-mailing to the seven-day rule 2) Quickly show delivery, receipt, acknowledgement, and acceptance of the LE and CD if asked by a third party 3) Provide an audit trail for the experience of the transaction to show how engaged a consumer was or was not in the case of a filed complaint JEff BodE ceo aND PreSiDeNt, MiD aMerica Mortgage Our biggest concern is meeting the various timing requirements. Even if we get everything else right, if we don't meet the timing requirements, we haven't met our compliance burden. Digital processes will be the key to ensuring accuracy, meeting the timing requirements, and providing an audit trail. We are re-examining all processes, looking for places where we can save keystrokes, eliminate time traps, and streamline workflow. Walking through today's workflow with a TRID mindset is critical to finding these potential "holes" and opportunities for engaging automation. The digital process and tracking of disclosure timing will also allow us to continue to offer timely closings to our customers with minimal effect from TRID. We also have to verify that our new processes are working as they should. This can be a challenge, since we can't officially flip the switch until October 3. As much as possible, we will be testing our new TRID processes in the background of our current workflow to reveal any unanticipated hiccups, such as unusual loan-specific scenarios or training issues that need to be addressed. We are also building a database of sample disclosure scenarios so that our employees will have examples to follow for atypical situations. Also, we are building job aids with quick reference type of information on TRID, which should save time that would otherwise be spent researching. As we reply to requests that come into our Compliance inbox, we are, in some instances, providing two responses–how the issue is handled today and, if applicable, how it will be handled under TRID. Furthermore, we are working with our LOs on how to educate customers regarding the importance of timely pick-up and review of their digital disclosures, especially the CD, to ensure an on time closing. Jon Johnson coMPliaNce officer, iDS Our message to lenders is to finish strong with their TRID preparations. First off, ensure you have the proper policies and procedures in place. Furthermore, your workflow needs to be hammered out at a departmental level. Every employee should know exactly how TRID will affect their job. For example, LOs should be aware that the LE needs to be sent within three business days. As the torchbearer for all TRID process deadlines, processors need to have a system in place to ensure consummation does not occur within seven days of the LE delivery date. Whatever entity is producing your closing disclosure (either an internal closer or a third-party provider), should be aware that the LE cannot be revised once a CD has been produced and that the closing cannot occur until three days after receipt of the CD. Finally, lenders need to be sure that their vendors' systems are communicating properly for the production of TRID documents. When running tests, are the systems performing as you expect they would? If possible, request a spectrum of loan file situations to test to ensure you're covered for a variety of scenarios. September is going to be a critical testing period. This is really the dress rehearsal before the October 3 go-live date, and everyone in your organization should be preparing to execute their role in all of this. Also, be sure to run through your most common loan programs, scenarios, and re-disclosure situations so that you are as prepared as possible for how TRID will alter these situations.

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