In an earlier post, we mentioned the new TILA-RESPA (TRID) integrated disclosure rule will take effect on August 1, 2015, and that mortgage originators should consider compliance training. It appears we beat NMLS, who recently released a newsletter asking whether mortgage institutes were ready to teach the new TRID rule, to the punch line. Fortunately for those interested in mortgage compliance training, Ameritrain has the instructors, approved TRID workbooks and multiple learning platforms to facilitate it. For those still catching their breath, the Consumer Protection Financial Bureau (CFPB) created a readiness guide to help mortgage professionals navigate the seminal rule.
In the readiness guide, the CFPB provides a litany of questions, which form the framework for an implementation plan. The first set of questions determine whether the TRID rule applies to your institution. These questions include: “Do you offer mortgage loans to consumers?”; “Do you offer closed-end credit or home equity lines of credit secured by a dwelling?”; “Do you service mortgage loans or own servicing rights?”; etc. Other questions address which products or services from your portfolio are affected, whether you’ve already created an implementation plan and finally a critique of your policies and procedures.
The policies and procedures section examines each product/service category and offers supplementary questions to ensure compliance. For example, loans that aren’t qualified mortgages fall under the Ability-to-Repay heading and include provisions that ensure borrowers have sufficient assets/income to pay back the loan. The policies and procedures section also looks at mortgage servicing rules, with emphasis on periodic billing statements, interest-rate adjustable notices for ARMs, force-placed insurance, etc. Finally, the guide then exhausts a host of other products and services that your institution may offer.
CFPB’s readiness guide also devotes a section to training, in which they ask whether mortgage institutions have determined what training programs need development, who needs training, whether training has been conducted, the formats for training and also the responsibility for developing course content.
Point being: the TRID rule is highly complex and readiness guides, such as the one reviewed above, demonstrate the extent of preparation needed on behalf of course providers to ensure compliance.