The deadline is approaching for compliance with “TRID 2.0.” The first TRID rules left us with lots of questions, but the 2017 changes have cleared up much of the confusion, while adding a few complexities.
Since December 29, 1987 banks have been required to develop and deliver Adjustable Rate Mortgage (ARM) program disclosures for each different ARM program offered. The disclosures must be updated at least annually.
Call it S.2155, Economic Growth, Regulatory Relief and Consumer Protection Act, EGRRCPA, or Public Law No: 115-174, deregulation by any other name is just as sweet. The sour part is, deregulation will be more work in the short run.
Both the Equal Credit Opportunity Act (ECOA) and the Fair Credit Reporting Act (FCRA) contain requirements for providing notice of action taken. This two-hour webinar reviews the requirements of both laws.
Paraphrased, here is what one circuit court said, “consumers are protected from a company’s deception, even if they never actually read its disclosures.” The world of compliance is different when you consider UDAAP whether with one or two “A’s”.