Access Our Bankers Library Vault for TRID Training

We turn regulations into plain english! Find out more below

Truth in Lending/RESPA Integrated Disclosures (TRID)

 

The TRID requirements were born from an overhaul of both the Truth in Lending Act (Regulation Z) and the Real Estate Settlement Procedures Act (RESPA-Regulation X) in 2013.  The TRID rules established new disclosure requirements for most closed-end, consumer credit transactions secured by real property (dirt) and compliance with the new rules was mandatory for applications taken on or after October 3, 2015.

 

This overhaul essentially did away with certain lending disclosures such as the Good Faith Estimate, Preliminary Truth in Lending Disclosure, HUD Settlement Statement, Final Truth in Lending Disclosure, etc. and combined them to create two new disclosures, the Loan Estimate and the Closing Disclosure.  The Settlement Cost Booklet was changed and is now called “Your Home Loan Toolkit”

 

The Final Rule summed up these disclosures and their purpose as follows:

The first new form (the Loan Estimate) is designed to provide disclosures that will be helpful to consumers in understanding the key features, costs, and risks of the mortgage for which they are applying. This form will be provided to consumers within three business days after they submit a loan application.

The second form (the Closing Disclosure) is designed to provide disclosures that will be helpful to consumers in understanding all of the costs of the transaction. This form will be provided to consumers three business days before they close on the loan.

The forms use clear language and design to make it easier for consumers to locate key information, such as interest rate, monthly payments, and costs to close the loan. The forms also provide more information to help consumers decide whether they can afford the loan and to compare the cost of different loan offers, including the cost of the loans over time.

In addition to these new forms, the TRID rules also implemented certain tolerance requirements for the fees disclosed.

BSA Training and Banking Regulations Compliance Consulting Spacer - TILA-RESPA Integrated Disclosures: Know Before You Owe. (NEW LANDING)BSA Training and Banking Regulations Compliance Consulting Spacer - TILA-RESPA Integrated Disclosures: Know Before You Owe. (NEW LANDING)

What You Should Know About TRID 

As mentioned above, TRID went into effect in 2015.  It is still fairly new and the kinks are still being worked out.  Any time you have a major overhaul of longstanding compliance requirements, there is typically a huge learning curve for financial institutions and regulators.  TRID is no different.

 

TRID underwent its first major change in 2017, in what we like to call TRID 2.0.  Compliance with TRID 2.0 was mandatory on October 1, 2018.  It implemented many amendments and also clarified some of the more confusing areas of TRID.  Some of the most notable changes/clarifications in TRID 2.0 pertained to the disclosure requirements for construction loans and what “in good faith” really means.  A Final Rule was also issued in 2018 to address when a Closing Disclosure can be used to reset tolerances.  In addition to formal regulatory changes, the CFPB has issued Small Entity Compliance Guides and additional resources to assist financial institutions in their compliance efforts.

 

TRID compliance is not easy.  The forms themselves can be quite cumbersome to complete; there are a variety of different timing requirements that must be met; file documentation is often a must to help show what you did and why; and accuracy is essential throughout the process to ensure tolerances aren’t exceeded, etc.  Not only that, financial institutions have to contend with software issues and changes, third party service providers (title companies, etc.), limited regulatory guidance on certain topics, etc.  Not every loan is the same and it seems that TRID issues can pop up at any time.

 

 

BCC TRID Training Resources: 

We are in the business of educating bankers and quality training is our top priority.  Our goal is to see you and your financial institution succeed!  You can be assured that everything we do, from in-person training and webinars to our magazine and blog, is done in our signature, plain English style.

 

In-person TRID training, whether it’s at one of our conferences or on-site at your financial institution, is as good as it gets.  The benefits of face-to-face training vs. other mediums are immeasurable.  Face-to-face communication not only allows you to “hear” the material but also to “see” it and “feel” it.  This personal interaction with both the presenters and other attendees/co-workers will stay with you long after the training ends.  Another perk of in-person, on-site training is that it can be customized to your specific wants and needs.

 

If you prefer a little more flexibility as to when and where you receive training, webinars are a great solution.  We have a wide variety of webinars for you to choose from devoted to specific TRID topics.  The shortened format of a webinar (1-2 hours) really allows us to go in-depth with laser-like focus on certain areas of the TRID requirements.  For example, if your lenders are struggling with completing the Loan Estimate and Closing Disclosure, we have webinars devoted only to form completion.  If you want to learn what you need to do when you have a changed circumstance or even what to look for when auditing a TRID file, we have a webinar for you.

 

Our blog is a great way to stay up-to-date with regulatory developments and topics.  If the CFPB issues a final rule affecting TRID, our blog is the first place we will tell you about it.  The blog acts as a great supplement to more formal methods of training and better yet, it’s FREE!

 

Our Banking on BCC Magazine is a must for any compliance professional.  This monthly, subscription-based, electronic magazine is chock-full of valuable compliance information each month.  We cover a variety of lending, deposit and BSA compliance topics from recent developments to highlighting areas that have maybe fallen off your radar.  TRID seems to be one of those regulations featured on a regular basis.  Each month, in addition to great articles, we also feature a Q & A Corner which highlights a few compliance questions we’ve recently received.  There are also BSA Bits & Pieces, a Management Minute and a Training Spotlight.

 

Our free resources include a treasure trove of helpful TRID information.  There are checklists, cheat sheets, timelines, and videos etc., all designed with the intent of helping you comply with the TRID rules.

 

Our Monthly Connection is yet another way to stay up-to-date on TRID issues and interact with your peers in the compliance industry.  While we talk about a wide variety of topics (that you have a hand in determining) each month, there is ample time to ask questions of our experts and also your peers.  We have always said, “compliance is not competitive” and our Monthly Connection is a way for compliance people to help other compliance people. 

 

There is no one-size-fits-all approach when it comes to a financial institution’s training needs.  That said, we do recommend some variety in the methods you choose.  Variety will not only help your budget but will give you different viewpoints.  Maybe you attend an in-person conference every couple of years and then fill in the gaps with webinars.  Maybe you follow the blog to monitor major regulatory developments and look to the magazine for more in-depth analysis.  The point is you can tailor training to your wants and needs.

 

External TRID Resources: 

Consumer Financial Protection Bureau

The Consumer Financial Protection Bureau (CFPB) has a wide variety of resources available on their TILA-RESPA Integrated Disclosures page.  These resources are designed to help the industry understand, implement and comply with TRID.  You can search for and browse any TRID applicable Final Rule that has been released.  There are also links to compliance guides, examination manuals, frequently asked questions and videos.

Access Our Bankers Library Vault for TRID Training

We turn regulations into plain english! Find out more below