When it comes time to sit down and audit your TRID loans, don’t forget to look at your online application process. TRID says you cannot require an applicant to provide anything beyond the six pieces of information (name, income, SSN, property address, property value estimate, and loan amount). It’s not uncommon, however, to see online application systems requiring more than they should. This 2 minute video explains the TRID guidelines for online applications and how they relate to the TRID rules, so don’t miss out!
Jerod explains more in the video.
TRID Guidelines for Applications Video Transcript:
Online applications, banks that take these, you need to make certain you review and confirm the online application process. We need to make certain that they’re not requesting something beyond the six pieces of information from a requirement standpoint. The request isn’t the right word. They do not require anything. So, we don’t have to ask for the six pieces all there, because remember we can strategically stagger that information so as not to have a completed app. But we cannot require them to complete any field beyond the six pieces. Now, our team throws grace at contact information because the lender needs to know how to contact the borrower if they’re going to submit something online. But outside of contact information, anything beyond the TRID-SIX, I believe, represents a problem and a violation of the rule.
Now, one of the things we run into with online applications is, if you’re an HMDA bank, you’ve got to collect race, sex, ethnicity, and a lot of information beyond that, at the time of application. And then, even for some non-HMDA banks, by way of Reg B, you’ve got to collect race, sex, and ethnicity. That has to be done at the time of application. We’ve run into some line platforms requiring the applicant to complete these fields before they can hit submit. The rule says from Reg B and HMDA that you have to ask the questions. Reg Z, truth and lending, which is where TRID resides, says, yeah, it’s fine for you to ask these questions because those other two regs require it, but you can’t require them to complete the questions. In other words, they have to be able to leave it blank. And that’s what we want to make sure that we’re looking for. And so, we test the system to make sure that we can submit an app without completing anything beyond the TRID-SIX. If we can’t, that is an implied requirement to move forward, and that’s not okay with the TRID rules.
Jerod is the leader of Banker’s Compliance Consulting’s training productions. He is a nationally recognized speaker. Whether it’s a conference, seminar, school, webinar, or luncheon, it’s easy to stay engaged when he presents due to the amount of passion and energy he brings to each and every compliance topic. Jerod has spoken on behalf of the American Bankers’ Association, BankersOnline, many state banking associations, private compliance groups, and financial institutions. He is a Certified Regulatory Compliance Manager (CRCM) and BankersOnline Guru.
Jerod likes to spend his time (between reading regulations and producing compliance training!) relaxing at the lake with his wife and three children, following their activities or engaged in something sports related!