When it comes time to sit down and audit your TRID loans, don’t forget to look at your online application process, TRID says you cannot require an applicant to provide anything beyond the six pieces of information (name, income, SSN, property address, property value estimate, and loan amount). It’s not uncommon, however, to see online application systems requiring more than they should.
Jerod explains more in the video.
Transcript:
For online applications, banks that take these must make certain you go out and review and confirm the online application process. We need to ensure they're not requesting something beyond the six pieces of information from a requirement standpoint. The request isn't the right word. They do not require anything. So, we don't have to ask for the six pieces because we can strategically stagger that information so as not to have a completed app. But we cannot require them to complete any field beyond the six pieces. Now, our team throws grace at contact information because the lender needs to know how to contact the borrower if they're going to submit something online. But outside of contact information, anything beyond the TRID-SIX, I believe, represents a problem and a violation of the rule.
Now, one of the things we run into with online applications is, if you're an HMDA bank, you've got to collect race, sex, ethnicity, and a lot of information beyond that, at the time of application. And then, even for some non-HMDA banks, by way of Reg B, you've got to collect race, sex, and ethnicity. That has to be done at the time of application. We've run into some line platforms requiring the applicant to complete these fields before they can hit submit. The rule says from Reg B and HMDA that you have to ask the questions. Reg Z, truth and lending, which is where TRID resides, says, yeah, it's fine for you to ask these questions because those other two regs require it, but you can't require them to complete the questions. In other words, they have to be able to leave it blank. And that's what we want to ensure we're looking for. And so, we tested the system to make sure that we could submit an app without completing anything beyond the TRID-SIX. If we can't, then that is an implied requirement to move forward, and that's not okay with the TRID rules.
Published
2022/12/16
