Trying to convert my auditing staff from old process to new process and realized I had some folks getting hung up on when Reg Z even applied. (I think that, in general, my shop is going to start struggling with the truly consumer-purpose cmml type loan and the consumer purpose loan to entities. But that rant is for another thread on another day.) So, we did some training in the audit dept and I decided to send a fun little end-of-the-week quiz. Just a simple, is this Reg Z or not and then is this TRID or not. Think it would be simple, yes? So, I had to think of some items that are Reg Z but not TRID. Easily done. Consumer purpose to a human but no dirt.

But then I got to thinking about RESPA. My RESPA audits are now concerned with the other sections of RESPA. Are there any loans that would still require a GFE going out? Reverse Mortgages? HELP me please before my head explodes. I have a whole new appreciation for you compliance officers navigating this on a daily basis.

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