TILA-RESPA INTEGRATED DISCLOSURE (TRID) A G E N T TOOL K I T
PURPOSE The purpose of this presentation is to provide First American Title agents with a high-level, 3 step outline to prepare for the August 1, 2015 launch of TRID.
INTRODUCTION More than just changing mortgage forms August 1, 2015, marks a major shift in the chain of events and the lender s liability on most residential real estate transactions. New integrated mortgage disclosure forms will be released that include new cost and timing tolerances as well as changes in the responsibility for their completion. Most importantly is a liability shift, both in statutory and punitive damages, should timing and cost tolerances fail to be met. As a title agent, it is imperative to begin engaging your lenders. Each lender will have different expectations and process for their transactions. Some lenders may rank settlement agents using a scorecard based on the agent s transaction performance and use that scorecard to determine if the agency is approved to handle their transactions.
3 STEPS TO AUGUST 1, 2015 ASSESS ACT GROW
STEP 1 ASSESS Over the last 12 months or longer, which banks have I closed the most loans with? Who are the lender s main points of contact (name, number, email)?» Loan Closers» Loan Processors» Do they have a TRID Hotline? Who are my top referral sources?» Attorneys (Representing banks, buyers and/or sellers)» Real Estate Agents» Lenders» Builders» Timeshares How compliant is my agency with ALTA Best Practices?» Where are my gaps?» Am I able to produce a Best Practice manual or certification if requested by the lender?» What is my current policy and time frames for issuing refunds, recording documents and issuing policies?
STEP 1 ASSESS (CONTINUED) How prepared is my software provider?» Will they support the new forms and the old HUD 1 form?» Will my software have an integration with Closing Insight? Assess your revenue risk, Owner s Policies will be listed as (optional)» How much did you write in Owner s Policy premium last year? Is my staff ready to explain value of an Owner s Policy? Are the real estate agents? How prepared is my staff to explain the Closing Disclosure (CD)?
STEP 2 ACT Train staff to:» Have basic knowledge of TRID» Understand the new forms and how they work» Explain why the CD and Settlement Statement figures don t match» Offer guidance to listing and buyer agents on the impact of the TRID Rule to their transactions» Calculate simultaneous title premium quotes» Manage multiple workflows, depending on the number of lenders» Gather and record the license number and Chief Compliance Officer information» Provide accurate information for the Loan Estimate and CD Ask my lenders the following questions:» Will you delegate me, as the settlement agent, to issue the CD? If so, in what form do you need proof of delivery of the CD?» Will you be operating on an electronic interface between the lender and the settlement agent? If so, what is the interface called and how do I access it? Will you require a settlement agent to be on that interface?» What will your real estate agent strategy look like?» How will you handle items paid outside of closing (P.O.C.)?» What will your new closing instructions look like?
STEP 2 ACT (CONTINUED) Ask my lenders the following questions:» How/when will you be able to do a dry run of the new process?» What are your timelines/dates I need to meet?» How many days prior to closing do you need the settlement agent s figures to allow enough time to issue the CD?» Who is our point of contact for TRID related issues? Chain of command?» What requirements are in place for changes to the CD at the closing table?» Is there an opportunity to attend training with processors?» Who is your Chief Compliance Officer, their license number and the license number of their loan officers?» What type of lender are you?» How do we deliver the seller s Closing Disclosure (2 page, 5 page)?» Are there any other requirements you have of me to continue to be your settlement agent? Address any back office operational changes needed to support lenders Complete settlement agent registration for Closing Insight TM at www.closinginsight.com
STEP 3 GROW From now until August 1, are you providing each party to a transaction, for both opened orders and closings:» TRID document about your agency s preparedness» Marketing flyer with educated staff, updated software, etc.» Email signature graphic with link to agency preparedness videos» Market anything above and beyond competition Host a real estate agent seminar and open house to discuss how TRID will impact their business As an agent, are you ready to absorb business from other agencies not able to comply with TRID? To put training materials, marketing materials and other TRID-related resources at your fingertips, visit the new Agency Resource Center tab in AgentNet.
TRID RESOURCES ALTA Best Practices www.alta.org/bestpractices ALTA Compliance Testing and Certification http://www.compliancesuccess.com AgentNet http://agency.myfirstam.com» TRID Training Click: Agency Resource Center > Integrated Mortgage Disclosure» Policies and Procedures CAP Click: Agency Resource Center > Best Practices