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Fred Gooch

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Every Financial Regulation is Under the Microscope

Posted by Fred Gooch on Feb 16, 2017 9:00:00 AM

Every Financial Regulation is Under the Microscope

What can lenders expect from Washington in 2017? 

 

Thought you finally had a grip on the CFPB’s regulatory agenda and major rule reforms? On February 3, President Donald Trump threw uncertainty back into the compliance mix with an executive order directing the Department of the Treasury to examine all of the laws and regulations governing the financial markets, including those set in motion by Dodd-Frank.

What does this mean for lenders still struggling to manage TRID, new fair lending laws, the upcoming HMDA revisions and other regulations?

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Topics: Compliance

Should Non-Purchasing Entities Sign the Closing Disclosure?

Posted by Fred Gooch on Feb 9, 2017 9:00:00 AM

Per its normal procedures, the Consumer Financial Protection Bureau (“CFPB”) requested comments on its proposed amendments to Regulation Z, commonly referred to as the “TRID Amendments.” In response, we provided a comment letter regarding these amendments, not only since they will impact our clients and ourselves once implemented, but also to share our expertise – cultivated through 25 years of providing vendor services – with the CFPB.

 

After posting a blog about our comments, we’ve received requests for more specifics as to their content. To oblige these requests, we are posting excerpts from our letter.

 

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Topics: Compliance

TILA-RESPA Integrated Disclosure Amendments and Disclosing Revised Amounts

Posted by Fred Gooch on Feb 7, 2017 9:00:00 AM

Per its normal procedures, the Consumer Financial Protection Bureau (“CFPB”) requested comments on its proposed amendments to Regulation Z, commonly referred to as the “TRID Amendments.” In response, we provided a comment letter regarding these amendments, not only since they will impact our clients and ourselves once implemented, but also to share our expertise – cultivated through 25 years of providing vendor services – with the CFPB.

 

After posting a blog about our comments, we’ve received requests for more specifics as to their content. To oblige these requests, we are posting excerpts from our letter.

 

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Topics: Compliance

HMDA is the Next Big Regulatory Wave Bearing Down on Lenders

Posted by Fred Gooch on Nov 22, 2016 9:00:00 AM

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Congratulations! You’ve survived TRID. You’ve adjusted to the Qualified Mortgage standards. All of your loan officers have been licensed in compliance with the NMLS standard.

 

But don’t relax now. The CFPB’s next wave-the Home Mortgage Disclosure Act (HMDA) – is bearing down. While the revisions to HMDA will be less intrusive than the recent TRID changes, this is still a major revision to a law that has not changed in more than a decade. The good news is that the standards do not go into effect until January 1, 2018. This gives lenders and their technology partners a little over a year to prepare.

 

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Topics: Compliance

Providing a Comment Letter to the CFPB – Docutech’s Take on Current Rules

Posted by Fred Gooch on Nov 3, 2016 9:00:00 AM

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As the Consumer Financial Protection Bureau (CFPB) works to refine the rules it has established for our industry, we are called upon to provide comments to help the Bureau work through that process, and having lived through the earlier iterations of the CFPB’s rules, it is in our best interest to do so.

 

Most recently the CFPB asked for comments on its TRID proposed changes, and we felt it was important to provide a comment letter because we have witnessed firsthand the struggles our clients have had adjusting to the TRID rules. It has become clear that the current rule still has much ambiguity that has caused some confusion in our industry. Over the past year, we have worked very closely with LOS providers and our clients’ internal counsel to provide automation that allowed them to operate according to their own interpretations of the rule, which varied widely.

 

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Topics: Compliance

Beyond TRID – Getting Ahead of 2017’s Other Compliance Changes

Posted by Fred Gooch on Oct 27, 2016 9:00:00 AM

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While the proposed changes to TRID are certainly generating a lot of attention from lenders planning their 2017 compliance priorities, there are several other developments lenders should keep an eye on. These other regulatory issues affect not only the documents used in applications and closings, but also in reporting the annual loan data required by the Home Mortgage Disclosure Act (HMDA).

 

By preparing now, lenders and their technology partners can ensure that there are no obstacles to smoothly rolling out the new requirements.

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Topics: Compliance

TRID 2.0 – Clearing the Clouds of Uncertainty

Posted by Fred Gooch on Oct 11, 2016 11:19:54 AM

TRID 2.0 – Clearing the Clouds of Uncertainty

 

After nearly nine months of watching lenders struggle to fully implement the TILA-RESPA Integrated Disclosures (TRID) regulations that went live in late 2015, the Consumer Financial Protection Bureau (CFPB) released a series of proposed amendments. While there are no large individual changes, depending on a business’s practices, there are several small tweaks that could greatly impact the lender’s processes and procedures.

 

Understanding what is – and what is not – in the proposed changes will help lenders prepare for the next phase of TRID.

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Topics: Compliance

They’re Baaaaack: CFPB to Reopen TRID Rulemaking

Posted by Fred Gooch on Jun 21, 2016 10:20:13 AM

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For much of the past 18 months, the mortgage industry has been solely focused on one thing—TRID. And although the TRID deadline has come and passed, the industry is not quite finished with the recent guidance. Just when you thought it was safe to get back in the water, the CFPB has reopened its TRID rulemaking.

 

According to a letter sent by Director Richard Cordray on April 28 of this year, the CFPB intends to revisit rulemaking for the TILA/RESPA Integrated Disclosure (TRID) rule, specifically around the Know Before You Owe mortgage disclosure forms. In addition, the Bureau announced the Notice of Proposed Rulemaking will most likely be issued in late July 2016.

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Topics: Compliance

Top Five Reasons Why Loan Data Synchronicity is Critical to TRID Compliance

Posted by Fred Gooch on May 3, 2016 3:34:18 PM

iStock_000084949291_Double.jpgIt’s already been seven months since the Truth-in-Lending/Real Estate Settlement Procedures Act Integrated Disclosures (TRID) went into effect. Many lenders were adequately prepared for the changes by integrating new technologies within their organizations. However, many lenders are still struggling to adjust to the “new normal” that is TRID compliance.

 

A common theme to the technology changes for many lenders who have successfully managed TRID is a focus on the seamless flow of data between the LOS, document management platforms and compliance systems.

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Topics: Compliance