Auditing TRID Application Dates
When it comes to compliance, the application date is often what triggers required disclosures. Problems can often arise because different regulations define an “application” differently. When you have a loan application that falls under the requirements of several different regulations, you have to be very careful. To demonstrate compliance with each regulation, you might have to document several different application dates. For example, Regulation Z says that you have a TRID application once you’ve received six specific pieces of information. Regulation B, on the other hand, says you have an application when you have an oral or written request for credit. Thus, if you use the TRID definition in providing Regulation B disclosures, those disclosures will often be made too late.
Jerod explains more in the video.
Published
2025/03/31
Jerod Moyer
Jerod is the leader of Banker’s Compliance Consulting’s training productions. He is a nationally recognized speaker. Whether it’s a conference, seminar, school, webinar or luncheon, it’s easy to stay engaged when he presents due to the amount of passion and energy he brings to each and every compliance topic. Jerod has spoken on behalf of the American Bankers’ Association, BankersOnline, many state banking associations, private compliance groups and financial institutions. He is a Certified Regulatory Compliance Manager (CRCM) and BankersOnline Guru. Jerod likes to spend his time (between reading regulations and producing compliance training!) relaxing at the lake with his wife and three children, following their activities or engaged in something sports-related!