Relying on Previous Flood Determinations

One question we get quite often is, “can we rely on a prior flood determination”?  In short, the answer is yes but there are three requirements you must meet.  The first is that the flood determination must be on a Special Flood Hazard Determination Form.  The second is that the flood determination is less than seven years old. 

Jerod explains the third requirement in the video.


TRID Changed Circumstances

It’s normal for changes to occur during the loan process.  If the loan is subject to TRID, however, you have to be careful.  Knowing whether you have a valid changed circumstance is very important and it dictates whether you can reset tolerances.  Are you handling changed circumstances correctly? 

TRID Changed Circumstance – Valid?

Question:  If we switch from a third-party appraisal in Section B to an internal evaluation fee in Section A that will ultimately cost less, do we need to re-disclose?

Answer:  Assuming the change is being made due to new or changed information (i.e. a valid changed circumstance), you will want to re-disclose the change in services within three business days, even though the cost is ultimately being reduced.  Otherwise, you take the risk that someone will see the new service in Section A as though you’re adding a service, even though it’s replacing the appraisal that was disclosed in Section B.

Question:  Can we change or even lock a rate after delivering a Closing Disclosure and if so, would we need to re-disclose?

Answer:  There’s nothing that prohibits the rate from changing after a Closing Disclosure has been delivered and nothing that prohibits you from locking a rate after the Closing Disclosure has been provided.  Remember, though, you could trigger a new three-day waiting period.  A revised Disclosure would be required if anything on the prior Disclosure became inaccurate.

Do you have more questions?  If so, be sure to JOIN US for our webinar, “TRID: Changed Circumstances & Revised Disclosures”. 


Compliance Conferences

Can you believe it’s already April?  It’s a little crazy to think we are just a little over five months away from our Fall Compliance Conferences.  We went 100% virtual last year due to the pandemic and had an outstanding response.  Thank you!

Based on your feedback, we will be offering virtual conferences again this year as well as the in-person event.  Mark your calendars!

Virtual Compliance Conference Series (includes all three virtual trainings below for one price!)

Lending – October 13 & 14

Deposit – September 28

BSA – November 10

Your virtual conference event will have two separate Zoom rooms, one training room and one other room where you can ask questions, etc.  You will also have the option to purchase the virtual conferences individually or the series of three at a discounted rate. 

A single registration gets your whole team in the Virtual Conference (unlimited locations at no extra cost)!

Banker’s Compliance Consulting submits their training (webinars and live events) to the ABA for CRCM Professional Certification approval. 

In-Person Compliance Conference

Omaha, NE – September 14 & 15

This In-Person event will cover the latest, greatest information related to Lending, Deposit AND BSA/AML compliance.  This event will feature a main training room, as well as a breakout room that will allow for concurrent training sessions.

For more information, be sure to check out our website or feel free to give us call/chat anytime.  We hope to “see” you one way or another!


HPML Baggage

Do you make high priced mortgage loans (HPMLs)? 

While that term seems to indicate they’re a bad thing, in reality they really aren’t.  HPMLs just carry a little more baggage than other types of loans you may make.  For instance, if you originate a first-lien HPML, you are required to escrow for taxes and insurance.  That’s just one of the several things you need to be aware of if you make an HPML. 

Find all your FREE Resources HERE!

Jerod explains the other things you need to consider in the video.

Be sure to JOIN US for our webinar, “Higher Priced & Higher Cost Mortgage Loans”. 


TRID: Sales Price vs. Estimated Property Value vs. Appraised Property Value

Page one of the Closing Disclosure provides a lot of different information about a loan transaction.  When it comes to the Closing Information section (top, left-hand side) there is a field where you are required to enter either the “Sales Price”, the “Estimated Property Value” OR the “Appraised Property Value”.  So, which one do you disclose? 

The answer is, it depends of a variety of factors.

Find all your TRID Resources HERE!

Jerod explains more in the video