TRID – The When and Why of Revised Disclosures Webinar
Dealing with revised disclosures has become one of the major challenges of TRID compliance. The frequency of revised disclosures is much greater than anticipated. The intricate timing requirements for the revision process are problematic. Just determining when a new disclosure may be given is not always clear. – see complete description below.
Click Here for Webinar Description and Audience
WHEN: The Consumer Financial Protection Bureau (CFPB) published a final rule to implement the Truth-in-Lending Act/Real Estate Settlement Procedures Act Integrated Disclosure (TRID) rules on November 20, 2013. TRID rules and guidance from the CFPB continue to evolve. One of the stated goals for the new integrated disclosures was to reduce the need for revised disclosures. No progress has been made on that goal; the frequency of revised disclosures has increased.
Dealing with revised disclosures has become one of the major challenges of TRID compliance. The frequency of revised disclosures is much greater than anticipated. The intricate timing requirements for the revision process are problematic. Just determining when a new disclosure may be given is not always clear.
WHY: Proper handling of revised disclosures can, in certain circumstances, reduce creditor liability. Mishandling revised disclosures can result in Truth-in-Lending Act violations and violations of Section 5 of the FTC Act (Unfair or Deceptive Acts or Practices). The rules are complex, and CFPB guidance on this aspect of TRID is lacking.
Some questions to consider:
- Are revised disclosures required or merely permitted?
- Is a revised disclosure allowed when no changed circumstance is present?
- What are the timing requirements for a revised Loan Estimate or Closing Disclosure?
- Does providing a revised disclosure always reset the permitted tolerance?
- What is the link between revised disclosures and UDAP/UDAAP liability?
This two-hour webinar answers these questions and provides a thorough review of the timing, content, and cure requirements for revised disclosures. TRID veterans and TRID rookies will benefit from this review of the rules for revised disclosures.
- The timing and delivery requirements of the Loan Estimate and the Closing Disclosure
- When a revised Loan Estimate may be issued; including situations such as changed circumstances, borrower requests, and expiration of terms
- When a revised Loan Estimate should be issued
- The timing and content rules for a revised Loan Estimate and for a revised Closing Disclosure
- Documentation requirements for revisions
- When estimates are considered to be “in good faith” and the applicable tolerances
- The circumstances under which a revised disclosure resets the allowed tolerance
- Changes before consummation that do or do not require a new waiting period
- Whether a changed circumstance can occur after delivery of the Closing Disclosure
- When refunds are required and how to make and disclose the refund
- Rules regarding changes due to events occurring after consummation; and
- How mishandling revised disclosures may result in UDAP/UDAAP violations
Who Should Attend?
Mortgage loan department managers, compliance officers, loan officers, auditors and others with responsibilities for preparing, delivering or auditing integrated disclosures
Click Here for Continuing Education Credits (CEC) Info
This webinar is recommended for 2.5 CE Credit Hours. Each attendee will receive a Certificate of Attendance for self-reporting of CE Credits.
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INCLUDES 7 DAYS OF ONDEMAND PLAYBACK! With this option, you will participate in the webinar (via the internet) as it is being presented. You will login to the webinar on your PC to view the PowerPoint presentation, and you have the option of using your PC speakers or a telephone for the audio. You can type and send your questions to the instructor. Many companies are now running their PC through an LCD projector allowing many employees to participate at the same time. And don’t worry if you miss the webinar, you can still view it for up to seven days after it takes place!
SIX MONTH ONDEMAND VIDEO:
With this option, you will receive an e-mail that contains a link to the PowerPoint slides (to download, print, and copy) as well as a link to the media player where you will view and hear the entire webinar just as it was delivered, featuring the full-color PowerPoint presentation with audio. You can pause, fast-forward and rewind as needed, which makes it an effective training tool. The weblink will be available to you (and anyone else in the company) for up to six months and can be accessed 24/7 as many times as you wish. Delivered via e-mail the day after the webinar takes place.
If you do not have internet access or want to make the webinar part of your training library, the CD-ROM Recording is a great option for viewing a webinar. You can pause, fast-forward and rewind as needed, which makes it an effective training tool. With this option, you will receive a download of the PowerPoint slides and a CD-ROM Recording (featuring PowerPoint presentation with audio) of the webinar via regular mail. Mailed 7 to 10 days after the webinar takes place.
Webinars can be scheduled and offered exclusively for your company. They can even be customized to best fit your needs. To find out more, please complete the in-house request form found in the Schedule and Registration Information section below.