TRID Issue Date
Back in November, we had our three-part webinar series on TRID From A to Z. As the title indicates, it was an opportunity for us to review TRID requirements from application through closing, all in a plain English format. Likewise, the questions you submitted help us to understand those areas that cause some confusion, regardless of whether we deal with them on a regular basis or just occasionally, and regardless of whether it’s something we’ve had to deal with since 2015 or something that recently came to light with TRID 2.0.
For example, the issue date on both the Loan Estimate and Closing Disclosure should reflect the date the disclosure is delivered to a consumer. Changing the issue date signifies that something has been changed or updated. Look at some of your Closing Disclosures – are you changing the issue date and if so, why? If a revised version of the disclosure was provided, you will want your file documentation to reflect why that was the case. In the case of the Closing Disclosure, if the issue date is changing even when the disclosure itself is not, you will want to change your practice. On the surface, this is a pretty technical issue, but you also don’t want anyone to be able to dispute when you provided the Closing Disclosure.
Our three-part TRID series webinar is still available for purchase if you are looking for some TRID training. Now, I’ll be honest, it’s a whole lotta TRID, but the good news is that with the recording, you can break it into shorter segments for what you have time for or for just how much TRID you want at one time. Find it in our Store today!
Diane Dean
Diane joined Banker’s Compliance Consulting with over 10 years of compliance experience and over 15 years of experience within the financial industry. Diane is a Certified Regulatory Compliance Manager (CRCM) and has a Bachelor’s Degree in Sociology with a concentration in Criminal Justice. She is a graduate of the Schools of Banking Compliance School and has participated in various other training opportunities throughout her career. Diane understands firsthand the struggles banks face in building and maintaining successful compliance programs. Her experience and common sense approach to consumer compliance is a great asset to our clients. Diane and her husband have two kids who keep them busy. She enjoys running and other sports and is a big Bugs Bunny fan! She’s a bit crazy in that she does enjoy reading some of these regulations and she’s a “crazy cat lady!” Her cat tales are hilarious!