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#2076272 - 04/28/16 09:19 PM TRID reopened
Need Coffee Offline
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Need Coffee
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Posts: 69
Down South
Is everyone excited about the CFPB reopening TRID rulemaking with a proposed new rule in late July? Has anyone heard possible scope? I really hope it is meant to address CP loans.
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TRID - TILA/RESPA Integrated Disclosures Rule
#2076331 - 04/29/16 01:53 PM Re: TRID reopened Need Coffee
Iowa Compliance Gal Offline
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Iowa
All I can say is here we go again! I have not heard any details but anytime they mess with procedures/regs it is not good. I agree maybe they will remove construction loans as TRID covered since they were not prior and should not be now.

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#2076333 - 04/29/16 01:54 PM Re: TRID reopened Need Coffee
rlcarey Offline
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Galveston, TX
should not be now.

Why not?
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#2076335 - 04/29/16 02:07 PM Re: TRID reopened Need Coffee
Iowa Compliance Gal Offline
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Iowa
Temporary financing.....I agree the perm loan should be subject to TRID but not the construction only phase.

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#2076338 - 04/29/16 02:24 PM Re: TRID reopened Need Coffee
RR Joker Offline
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The Swamp
They are going to make me go crazy. Who can keep UP with all the poking around and new major changes to rules. Just freaking leave well enough alone!

Why shouldn't construction loans, or any other temp RE loan be covered? It's quite often the largest investment a consumer will undergo!
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#2076343 - 04/29/16 02:48 PM Re: TRID reopened Need Coffee
RR Becca Offline
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out of the frying pan...
Besides, it's easier to train staff when the rule is "all in" instead of having to sort out what applies and what doesn't.
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#2076346 - 04/29/16 02:55 PM Re: TRID reopened Need Coffee
Jen J Offline
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I wouldn't mind them cleaning up the title insurance nonsense.

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#2076347 - 04/29/16 03:00 PM Re: TRID reopened Need Coffee
Iowa Compliance Gal Offline
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Iowa
We had a flat rate $2500.00 costs plus 1% origination fee construction loan.....all of our vendors agreed to the fees they would charge and if by chance it went over the flat fee of $2500.00 due to abstracting or an unforeseen charge the bank would eat the overage so we were the same as TRID before it's time on construction loans.

If we did not do a flat rate then I could see it but in our case was not necessary we accomplished the same thing. Got me on the training on "all in" much easier in the long run. We were all just getting the hang of how things are done and now have to re-train, shoot me now!!!

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#2076348 - 04/29/16 03:03 PM Re: TRID reopened Iowa Compliance Gal
fmissle Offline
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Joined: Jul 2007
Posts: 989
Pac NW
Originally Posted By Iowa Compliance Gal
All I can say is here we go again! I have not heard any details but anytime they mess with procedures/regs it is not good. I agree maybe they will remove construction loans as TRID covered since they were not prior and should not be now.


I disagree. I don't want to, because we don't do perm loans here but do construction. If construction loans weren't included, I could kiss TRID goodbye until we started down a path of offering something.

But I like the easy (Dirt+Consumer Purpose+Closed End=TRID) rule and I do think there is valuable information for the customer in the disclosures.
I dislike a few things about the rule, but after working with it for just 6-7 months live I feel I have a decent grasp on it and will get better as we move forward.

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#2076352 - 04/29/16 03:20 PM Re: TRID reopened Need Coffee
Ohmyachinghead Offline
Junior Member
Joined: Sep 2015
Posts: 40
Oklahoma
Im with Iowa Compliance Gal. I finally got everyone on the same page and pretty much comfortable (as much as we can be) with what to do. So with any changes it will be "Uh you know what I told you about (whatever), just disregard that". Pass the pain meds!!

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#2076354 - 04/29/16 03:24 PM Re: TRID reopened Need Coffee
rlcarey Offline
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Galveston, TX
They are not going to make sweeping changes. They said they want to re-open it to add additional guidance that has been presented in the various webinars. This will also present an opportunity for the industry to request additional guidance on any number of issues that remain unanswered. The industry should be embracing the opportunity rather than trashing it.
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#2076361 - 04/29/16 03:37 PM Re: TRID reopened Need Coffee
RR Joker Offline
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The Swamp
Well that's good to know. Thanks for being the voice of actual reason, Randy crazy
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#2076515 - 04/29/16 10:32 PM Re: TRID reopened Need Coffee
Darth HMDA, CRCM, CAMS Offline
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Darth HMDA, CRCM, CAMS
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Posts: 1,387
CA
I agree with Randy... could it cause some headaches... sure

However, this is done at the request of the industry as a whole and hopefully will provide clarification on a number of areas that make me lose sleep at night. Hopefully it goes well. smile
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#2076522 - 04/29/16 11:40 PM Re: TRID reopened Need Coffee
rlcarey Offline
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Galveston, TX
Well, some of what we are dealing with is really our own fault. Of the people that have participated on this thread, how many of your institutions actually commented on the proposal in Aug 2012? or let alone read it? There were 2,921 comments submitted. I don't know how many banks or industry groups commented, but some of the comments included:

- Adding some color could help break up the sections. - Independent

- The more you guys get involved, the more confusinng it gets... I have been in the business almost 17 years. The new disclosures I can see my consumers eyes glaze over everytime I go over these new disclosures. I have to go over them 3-4 times, thye still usually dont get the logistics of it. Was much much easier for the consumer with a 1 page GFE. Learn how to put all this on 1 page and you will be much better. Will there be a day when we have a 150 page GFE to explain? - Landover Mortgage

- After review of your sample before and after disclosures, I feel they are an improvement. These should help clients understand the financing regardless of their background training. I especially appreciate the reduction in paper needed.Will you also help reduce the number of disclosures needed for a home loan? - American Pacific Mortgage

- I work at a small bank, and we have many customers that choose to use our current Balloon Loan Product, or their property may not qualify for secondary market financing, or the loan is small and closing costs would be too high to go secondary market. There are many situations that a balloon loan may be a better option for customers. Please consider to allow Balloon Loans. There are many banks that use Balloon Loans. - State Bank of Chilton

This is the quality of the comments the CFPB received. What did your letter say?

There were 6,110 commercial banks in the US at the time the proposal was out and the CFPB received very few significant comment letters on the actual substance of the disclosures, problems that their proposal would cause, areas where there was no guidance or the instructions were confusing, etc..

Maybe we can do better this time around?
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