The mortgage industry is still coming to terms with the day-to-day tasks of maintaining TRID compliance. But other, broader systemic risks still loom, which, if overlooked, could significantly disrupt lenders’ operations.
For instance, there may be more riding on the accuracy of initial closing cost estimates in the new Truth in Lending Act/Real Estate Settlement Procedures Act Integrated Disclosures than mortgage lenders realize.
“People can make mistakes. They can forget to put a charge on the form. Sometimes charges are manually inputted and that can lead to a disclosure with an inaccurate estimate. But if the CFPB sees a pattern or practice of these, that’s when you can really get into trouble,” said Richard Horn, a former Consumer Financial Protection Bureau senior counsel and special advisor who led the final TRID rule.
Overestimating’s Hidden Cost
At first glance, TRID estimate deviations sound simple […]