What You Should Know About TRID and TRID Guidelines
TRID went into effect in 2015 and, even today, 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 Consumer Financial Protection Bureau (CFPB) has issued Small Entity Compliance Guides, FAQs, 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, but financial institutions also 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.
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. Webinars (1-2 hours) allow us to go in-depth with a laser-like focus on key 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 about changed circumstances, construction loans, or even what to look for when auditing a TRID file, we have a webinar for you.
Banker’s Compliance Consulting offers many options for risk-based compliance reviews. We offer full compliance reviews, including deposits, loans, and an independent BSA Audit. Several retainer packages are available to fit your institution’s size and needs. We can thoroughly review your institution’s lending and deposit operations on a quarterly, semi-annual, or annual basis. If you’d like a customized solution, we can review any combination of these regulations, such as a targeted HMDA review, TRID review, or website compliance review. We also offer exam preparation, comprehensive compliance risk assessments, compliance assistance on mergers, internal monitoring guidelines, and policy review and development. We provide off-site and/or on-site reviews based on your preference. Whether it’s providing documents electronically through a secure portal or providing paper or electronic files in your institution for review, we can customize a review solution that works for you!
Our blog is a great way to say up-to-date with regulatory developments and topics. When there are new developments affecting TRID, our blog is the first place you will hear from us. 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 always chock-full of valuable compliance information. We cover a variety of lending, deposit, and BSA compliance topics, from recent developments to revisiting areas that have maybe fallen off your radar. 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 regular features such as BSA Bits & Pieces, Management Minute, Field Notes, and a Training Spotlight.
Our free resources are a treasure trove of helpful information designed with the intent of helping you comply with lending regulations. We have many free tools and resources. Simply use the search bar to find exactly what you are looking for; you may find other resources that are also helpful.
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 help determine) each month, there is ample time to ask our experts and your peers' questions. 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 wants and 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 our magazine for more in-depth analysis. The point is, you can tailor training to your wants and needs.