Article by: Ben Giumarra, Spillane Consulting Associates, Inc.
Quiz your team on the most recent TRID update.
If the definition of “loan originator” is broader under TILA than under the SAFE Act (which it is), why do so many institutions have more NMLS-licensed employees than true originators (who are subjected to TILA qualification, compensation, and training requirements?).
The most recent TRID update was finalized last Friday. The mandatory compliance deadline is October 1, 2018. At a frightening 560 pages, this is a lot to handle. The good news is that much of this we’ve been prepared for. Someone keeping up with compliance alerts shouldn’t be caught off guard by too many of these.
Test yourself, or your team, by taking the following quiz. Check in for answers next week!
TRID Quiz: July 2017 Updates
Using the heading/topic below only, explain in a sentence or two the applicable part of the July 2017 Rule (which you can read here – and if 560 pages is too much for you, the 12-page executive summary should be perfect for you.)
As best as I can count, there are more than 30 changes from this rule. So being able to correctly explain even a majority of the following topics would be impressive. *I completed a couple of these as examples.
- Calculating cash to close table
- Construction loans
- Decimal places and rounding
- Escrow account disclosures
- Escrow cancellation notices
- Informational updates to the Loan Estimate*
The Rule confirms that lenders can provide revised Loan Estimates voluntarily for so-called “informational purposes,” but noted that in doing so lenders would be held to the standard of best information reasonably available.
- Expiration dates for the closing costs disclosed on the Loan Estimate
- Gift funds*
The Rule clarifies that we only disclose gift funds to be received at closing. We do not disclose gift funds received prior to closing.
- Lender and seller credits
- Lenders’ and settlement agents’ respective responsibilities
- Settlement Service Provider List
- Non-obligor consumers
- The “Black Hole” Issue*
Trick question – the Rule does not address this issue. Instead, a separate rule was issued on the same day that merely proposes a new fix for this. That means we’re back at square one.
- Simultaneous second lien loans
- The summaries of transactions table
- Total interest percentage calculation
- Trusts
- Lender and seller credits
- The “In 5 Years” calculation
How many can you get??
In Other News
- Ever wonder how profitable you are? It’s hard to make strategic decisions without a clear understanding of your finances. And calculating the cost to originate a mortgage can be exasperating. Don’t forget my colleague Greg Smith specializes in this – giving you a solid assessment here is quick and easy for him. Give him a call sometime to discuss!
- American Banker article (subscription required) on AG Sessions plans … senators state that despite some assurances that the Department of Justice crackdown on banks’ third-party relationships was ending, it is still having an impact.
- 3D printers are now printing firearms … that’s nothing, I’ve had a Canon printer for years.
On My Mind …
A person can have a negative or positive impact on others. Shocking news, I know. But Daniel Goleman puts a little more interesting spin on this, in his book Social Intelligence, when he describes what he calls the “emotional economy.”
Every interaction has an emotional subtext. Along with whatever else we are doing, we can make each other feel a little better, or even a lot better, or a little worse–or a lot worse… Beyond what transpires in the moment, we can retain a mood that stays with us long after the direct encounter ends–an emotional afterglow…
These tacit transactions drive what amounts to an emotional economy, the net inner gains and losses we experience with a given person, or in a given conversation, or on any given day. By evening the net blance of feelings we have exchanged largely determines what kind of day–“good” or “bad”–we feel we’ve had.
“And if you’re going to be a leader, you know what I ask myself? Would I want to work for you in this job? Would I let my children work for you? Would I give you this job if I wasn’t there to provide oversight? If you went to run another company, would I, as an investor, invest in that company?”
– Jamie Dimon
Thank you to Ben Giumarra, Spillane Consulting Associates, Inc., a member of our Education Committee, who with the support of other experts at SCA have put together this newsletter.