I am updating my bank’s RESPA policy and can't make up my mind how to proceed...

The current policy still references the GFE and the Special Information Booklet; but provides an exemption to those requirements for transactions falling under TRID. I started thinking about this structure and the only scenario I can think of that would require a GFE/early TIL instead on an LE is a Reverse Mortgage since it is exempt from TRID.

My bank does not originate reverse mortgages nor does it have plans to in the future. I am thinking about stating these facts (in a more professional way of course) in the policy and not including anything about GFEs or special information booklets since ther are irrelevant to my bank's business.

Does anyone see any major risks with this? Am I missing something?

I am going to ask a simple question, Why would you have a RESPA Policy? Or are these more desk procedures.

Goo point osucpa. I wonder the same. Sounds like a lot of work (to keep it up to date as iLovetheVols testifies) for very little benefit.

"What", "Where", "When" and "Why" are generally policy issues, should be concise and rarely change

"How" is a procedures issue and changes with people, systems, regulations changes, time of day and attitude,. is more complex and detailed..

I totally agree that the bank should have a consumer lending policy instead that rolls all consumer lending regulations into a concise policy, however... I just started at this bank and they have always had a compliance policy for each regulation and I am simply updating existing policies per assignment. I have only been at the bank for a month so I don't have a lot of leverage yet. I will suggest the idea to my manager though.

If I am required to update the RESPA policy (that details required disclosures), does anyone have any feedback on my original question?

Thanks!

My suggestion only, I would sit down with your manager and try to explain the amount of wasted time being utilized updating each of these compliance policies. Recommend most of this information be moved into desk procedures.

the only scenario I can think of that would require a GFE/early TIL instead on an LE is a Reverse Mortgage since it is exempt from TRID

What about a consumer purpose loan to an entity?

Excellent point. A federally related mortgage loan is not limited to natural persons (and consumer purpose trusts) like TRID is. I will need to include references to the GFE and the Special Information Booklet. Thank you rlcarey!