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#2024932 - 07/03/15 11:54 AM Less than cooperative software vendors - TRID
Anonymous
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I'm going to try very hard to not mention software vendor names, but has anyone else run into a major software vendor saying they won't be providing the Escrow Closing Notice....ever, and inviting the bank to design an Escrow Closing Notice themselves using the report writer. This is so unbelievable that I thought I'd find out if anyone else has run into this. How would you handle? This isn't some mom-and-pop software company, either, this is a major provider of core systems.

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#2024945 - 07/03/15 12:29 PM Re: Less than cooperative software vendors - TRID Anonymous
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 83,227
Galveston, TX
The Escrow Closing Notice is not part of TRID and it is probably not going to be a form that a bank will use very often. I'm not sure why you have your shorts in a bunch over it.
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#2025016 - 07/03/15 02:10 PM Re: Less than cooperative software vendors - TRID rlcarey
Anonymous
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Different anon here.

The escrow closing notice was provided for in the TRID final rule and it is discussed in the CFPB's Compliance Guide for TRID. The discussion of the notice begins on page 83 of the guide. It is a disclosure that would need to provided, if applicable, when the escrow account is closed under certain circumstances during the servicing of the loan. I know we had to create our own ARM adjustment notices in our core system so I'm guessing we'll have to do the same for the escrow closing notice.

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#2025031 - 07/03/15 02:41 PM Re: Less than cooperative software vendors - TRID Anonymous
Gioia Offline
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Joined: Sep 2014
Posts: 82
I don't know that I see the big issue, core providers don't supply every letter out there, but still give you the ability to write your own and use their system to import account info into your letter. Using the letter is going to be a pretty rare occurrence around here, and that is probably true for many banks that use the same core provider as us, so I am hardly in shock that it isn't being offered.

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#2025068 - 07/03/15 03:47 PM Re: Less than cooperative software vendors - TRID Anonymous
Anonymous
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RLCarey, the Escrow Closing Notice is part of TRID. See the CFPB small entity guide and their training PPTs that they've offered.

15.1 Does TILA-RESPA require any other new disclosures besides the Loan Estimate and Closing Disclosure?

Yes. In addition to the Integrated Disclosures discussed above, the TILA-RESPA rule also changes some other post-consummation disclosures provided to consumers by creditors and servicers: the Escrow Closing Notice (§ 1026.20(e)) and mortgage servicing transfer and partial payment notices (§ 1026.39(a) and (d)).

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#2025217 - 07/03/15 08:44 PM Re: Less than cooperative software vendors - TRID Anonymous
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 83,227
Galveston, TX
I guess that depends on how you define TRID.

True, it came out at the same time.

However, the TRID disclosures (LE and CloD) were specifically required to be developed by the CFPB under Sec 1032 of the DFA.

The escrow closing disclosure is something that the CFPB cooked up on their own under Sec. 1405(b) of the DFA.
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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