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TRID Dominates QC Issues in 2016

Lenders finish first full year of TRID

March 8, 2017

By Mortgage Daily staff

Most of the quality-control issues experienced by home lenders last year were tied to disclosures implemented by the Consumer Financial Protection Bureau.

Combined mortgage disclosures required by the Truth in Lending Act and the Real Estate Settlement Procedures Act went live in October 2015.

The TILA-RESPA integrated disclosures replaced the Good Faith Estimate with a Loan Estimate and the HUD-1 Settlement Statement with a Closing Disclosure.

During 2016, the first full year of the rule's implementation, TRID accounted for 12 of the the top-15 findings of QC issues, according to MetaSource LLC.

The Salt Lake City-based third-party compliance service provider said it based its findings on a review of thousands of post-close QC audits.

"TRID was such a significant change and many loan origination systems weren't completely ready for it," MetaSource Senior Vice President of Mortgage Services Mary Kladde said in the news release. "Additionally, QC was largely left out of the thought process."

Kladde noted that the time sequence of new documents required for fee changes between the initial and final Closing Disclosure and Loan Estimate was one source of confusion. This was especially true when they had the same date.

The top issue was correspondence of information listed in the Calculating Cash to Close table on page three of the Closing Disclosure to the information cited on the last disclosed Loan Estimate.

Next up was the receipt of the Closing Disclosure by the borrower at least three business days prior to consummation.

"The top two findings deal with difficulty in calculating the homebuyer's income," Kladde said. "FHA and Fannie Mae have often found these to be problems as well."

After that was providing the Closing Disclosure in the file for review, then curing unjustified fee increases within the zero-tolerance category.

Next was handling revised Loan Estimates and providing the Loan Estimate to the borrower within three business days of the application.

MetaSource said the leading non-TRID QC issue was was providing verbal verifications of employment according to automated underwriting system requirements.

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