FHLB Mortgage Partnership Program Issues Reminder for TRID Compliance
By Anna DeSimone
July 13, 2015, the Federal Home Loan Bank (FHLB) issued PFI Advisory 7-13-15 entitled: The MPF Program Reminds PFIs to be Prepared for the TILA-RESPA Integrated Disclosure Rule, Coming Soon.
- Have you tested new processes, procedures, or systems?
- Have you trained your staff to comply with the Rule?
- Have you considered how you will use the new Your Home Loan Toolkit that is replacing the Settlement Cost Booklet?
- Have you contacted your vendors to ensure they will be ready to comply?
- Have you developed a strategy for coordinating and communicating with all parties involved in a mortgage loan transaction (i.e. the buyer, seller, loan officer, real estate agent, title company, and settlement agent)?
- Have you consulted with your legal counsel and/or compliance team?
- Have you developed an alternative plan of action if you or your vendors are not ready by the effective date of the Rule?
- Have you created a strategy to monitor your institution and your vendors’ continued compliance with the Rule even after the implementation date?
NOTE: If your institution is out of compliance with applicable laws, including the Rule, the MPF Program will not purchase any loans from your institution while it remains out of compliance. Additionally, any loans delivered under the MPF Program that do not comply with applicable laws are subject to repurchase.
Resources
MPF University. The MPF Program is offering the free online audio courses below through MPF University to introduce PFIs to the integrated disclosure forms. PFIs may register for these courses at MPF University under Available Courses. The courses are accessed with the Audio On-Demand link.
The preceding general discussions of the Rule do not constitute and are not intended to be relied on by PFIs as legal advice with respect to the Rule or its applicability. Each PFI is expected to consult with its own counsel for advice concerning the Rule and its applicability. If you have any questions or concerns about your institution being ready to comply with the Rule, please contact your MPF Bank Representative immediately.
Please refer to the PFI Advisory for additional resources provided by the CFPB.
About the Author
Anna DeSimone is President and Founder of Bankers Advisory and Principal of CliftonLarsonAllen LLP. She can be reached at anna@bankersadvisory.com
Anna DeSimone founded Bankers Advisory in 1986 and is a nationally recognized authority in residential mortgage lending. She has received numerous industry awards and has authored more than 40 best practices guides and hundreds of articles.
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