Efficiently and effectively implementing the changes needed by October 3rd will be a challenge. Here are three action items for lenders to complete with their AMCs before the go-live date:
- Develop and document your interpretation of TRID. What is your definition of a change circumstance? How do you interpret zero tolerance? Having your interpretations documented is an important step to a repeatable process.
- Engage your AMC in a comprehensive assessment of TRID. How are they going to ensure appraisers are paid a Customary and Reasonable fee per Dodd Frank regulations while complying with TRID’s zero tolerance rule. What options can they provide to you the lender to ensure C&R and TRID requirements are met? There will be many surprises after October 3rd, the more that you can anticipate now and document responses with your AMC the better.
- Align your processes with the new regulatory reality. Different lenders are taking different approaches on how to be compliant. Make sure your AMC is flexible enough to execute in a way that meets your needs.
Pro Teck is working with a number of lenders helping them meet the challenges of TRID. If you would like to learn more or have us review your TRID readiness, please reach out to your Pro Teck Representative or fill in the below form.