CFPB & TRID regulations are now upon us! As of October 3rd any loan applications submitted will fall under TRID (TILA RESPA Integrated Disclosures) regulations. If you have a lender that you refer business to Independence Title Co encourages you to have coffee or lunch with them to find out how your lender will be conducting business with the new rules & regulations.
Over the last 10 months we have spoken with numerous loan officers, processors, attorneys, and compliance departments and each lender may interpret TRID regulations differently from one another. Here is a list of questions to get the conversation started with your favorite lender.
Q: Who prepares your Closing Disclosure?
• Most lenders are taking on this responsibility
• They are responsible for the accuracy of the Closing Disclosure
• They are also responsible for adhering to the strict timeline for delivery
Q: How will you deliver the Closing Disclosure to the consumer?
Delivery method can impact closing date
• USPS mail may require up to 7 days
• Overnight delivery may require up to 4 days
• Hand delivery or electronic delivery may require 3 days
Q: Do you require a signature on the Closing Disclosure to start the 3-day review period?
• It is not in the regulations that the consumer must sign the Closing Disclosure
• Lenders may or may not want a signed copy returned
Q: Can I get a copy of the Closing Disclosure from the lender?
• The regulations state that the Closing Disclosure to the consumer
• The Texas Association of Realtors created an Authorization Form for consumers to give authorization for their Realtor to receive a copy of the Closing Disclosure
• Some lenders may not accept this form but they might have a similar form to allow the Realtor to receive copies of the disclosures
Q: What is your contract to close turn around time?
• Most lending professionals agree that a 45 day turn around time is realistic
• By early 2016 we might see a 30 day contract to close timeline
Q: Tell me about your pre-qualification/pre-approval process?
• Prior to the CFPB there was a regulation in regards to pre-qualification/pre-approval process in existence but it was mostly overlooked
• The rule stated that a lender cannot require upfront documentation prior to a bone-a-fide loan application
• With CFPB audits right around the corner some lenders may be changing their pre-approval process
• Consumers may voluntarily provide upfront documentation for pre-approval
• See our Consumer’s Guide Brochure
For more information on CFPB check out our related blog post
Our Online Calculators ready for the New Regulations