10 Details to Double-Check During the Final Countdown to TRID
Published September 29, 2015 4:41 PM
1 Min Read
With the implementation date for the TILA-RESPA Integrated Disclosures just days away, here's a look at some of the finishing touches the mortgage industry is making to its technology and training preparations. For many lenders and vendors, this week will be filled with frantic activity as they test and retest process, procedure and technology. But others say they are not worried at all about being ready on Oct. 3.
Testing One, Two, Three
"We've got quite a bit of last-minute activity happening. Most notably, all of our customers are finishing their coding of the data fields
[and] are banging away at our test environments, looking at every possible loan scenario, making sure the resulting output is as expected," said Jonathan Kunkle, president of GuardianDocs, a division of LenderLive.
Dot the i's, Cross the t's
"We are doing user acceptance testing with our lender partners, especially to the [loan origination systems] integrations we have," said Dan Mugge, senior vice president of program development at closing cost data provider ClosingCorp, who added that additional testing is being done at the vendor's request.
At the Last Minute
ClosingCorp is also doing a last-minute technology update. "We have a final release Thursday night. There [are] a couple of things we didn't want to introduce until right before [the deadline] that we'll configure Thursday night," said Mugge.
The New Math
"I think, like most things, we got it 90% right, but there will be a 10% adjustment period," said Brian Coester, chief executive officer of CoesterVMS. The appraisal management company has created a calculator for originators to use to determine the appraisal fee, but can't see how the calculator works in real-life scenarios until after implementation.
This Is Old News
Rafael Castellanos, managing partner of Expert Title Insurance Agency, is less concerned about being ready. "All of these new rules and regulations I mean come on. We've known about them for at least two years, if not longer. So anyone who just stuck their head in the sand, well shame on them," he said, adding the only change his company is making this week to its website is to add a price list.
Being Prepared Means No Surprises
"If we weren't prepared right now, we'd be in deep trouble. But, systems, processes have been in place, we've fully tested them out, run additional scenarios through and we're taking feedback from our sales team relative to scenarios. We do not foresee any major challenges," said Al Crisanty, Michigan Mutual's director of wholesale lending.
May I Help You?
Michigan Mutual has created a central disclosure desk to handle mortgage broker questions about the change, because there will be variations among wholesalers about the process. "Brokers are trying to figure out who's doing what [and] how they're doing it. There are differences that are easily handled, you just have to be aware of them," said Crisanty.
Nothing to Be Afraid Of
Steve Beecham, owner of Home Town Mortgage, a broker in Alpharetta, Ga., went to a class last week on TRID. "I really didn't see it to be that big of a deal. It didn't scare me as much as much I as I thought it was going to. So I feel a lot better about it." He is waiting for Calyx Point to issue an update, and that will be the only system change this week.
A Smooth Ride Ahead
Michael Deery, the owner of Citywide Financial Corp., a San Diego broker, also isn't worried. "There may be a few speed bumps at the beginning, but once we get through the first few files, it will just be part of the new loan process."
It's a Marathon
People shouldn't expect to be done with the implementation once the switch is thrown on Oct. 3, said Kunkle. The Consumer Financial Protection Bureau continued to make changes to the servicing rules for months after implementation in January 2014, he pointed out. "We lived through the Reg X changes which were just as cataclysmic as this change. We went through Reg X hangover for a number of months as the rules continue to change. We're fully expecting that for TRID."
