Monthly Archives: February 2019

Changes to LO Compensation on the Horizon ?

The year 2019 will bring big changes to the financial services industry. Kathy Kraninger’s recent confirmation as Director of the Consumer Financial Protection Bureau understandably raises hopes that that this year will see a rebalancing of the key mortgage regulations to expand credit availability and maintain key protections for consumers, while lessening burdens on industry. The MBA has outlined many such changes in our responses to the Bureau’s requests for information or RFIs. That exercise also made clear that changes to the LO Comp rule should be the Bureau’s top priority this year.

Loan Originator Compensation (LO Comp)

The original impetus for the LO Comp rule was to protect consumers from steering. In the current regulatory environment, the harm associated with steering—borrowers agreeing to a loan they do not understand and cannot repay—is less likely. The LO Comp rule obviously plays a part in this, but so does the other regulatory actions adopted following the passage of the Dodd-Frank Act. After more than five years under the rule, it is clear that certain limited changes should be made to retain core consumer protections while enabling a more competitive and transparent market.

The LO Comp rule, while well-intentioned in conception, is causing serious problems for industry and consumers because of its overly-strict prohibitions on adjusting compensation, and the amorphous definition of what constitutes a “proxy” for a loan’s terms or conditions. These harms are felt when borrowers are unable to obtain lower interest rates from their lender of choice when shopping for a mortgage, or when lenders are unable to hold loan officers accountable for errors in the origination process.  Consumers are also harmed when lenders limit their participation in special programs designed to serve first-time and low- to moderate-income borrowers. Three important changes could address these problems:

Change One: The Bureau should allow loan originators to voluntarily lower their compensation in response to demonstrable competition in order to pass along the savings to the consumer.

The Bureau’s rule provides that a loan originator’s compensation may not be increased or decreased once loan terms have been offered to a consumer. This provision is designed to eliminate financial incentives for a loan officer to steer a consumer to a higher interest rate or a higher-cost loan.

However, the rule as implemented has the effect of prohibiting reductions in compensation that could otherwise be passed along to the consumer in the form of a lower-priced, more affordable loan. This also has the effect of reducing the consumer benefit that comes from shopping across multiple lenders in order to negotiate the best interest rates and other terms.

Currently, in such situations, a lender must decide between lowering the interest rate, fees, or discount points to meet the competition (and thus possibly originating an unprofitable loan with the fixed loan originator compensation), or declining to compete with other loan offers. The requirement to pay the loan originator full compensation for a discounted loan creates a strong economic disincentive for lenders to match interest rates. For the consumer, the result is a more expensive loan or the inconvenience and expense of switching lenders in the midst of the process. This anti-competitive feature impedes loan shopping and discourages price competition. Clearly this is contradictory to the stated aims of the Bureau’s Know Before You Owe/RESPA-TILA Integrated Disclosure rulemaking, which seeks to encourage shopping and empower the consumer to negotiate.

To address this unintended outcome, we urge the Bureau to amend the rule to permit lenders to respond to demonstrable price competition with other lenders by allowing the loan originator to voluntarily reduce his or her compensation in order to pass along the savings to the consumer. This change would significantly enhance competition in the marketplace, helping lenders to compete for more loans, while also benefiting consumers who may receive a lower interest rate or lower-cost loan offer.

Change Two: The Bureau should allow lenders to reduce a loan originator’s compensation when the originator makes an error.

The LO Comp rule currently prevents companies from holding their employees financially accountable for losses that result from mistakes or intentional noncompliance with company policy when they make an error on a particular loan. As it stands, a loan originator who is responsible for an error may not bear the cost of that mistake when the loan is originated. This result runs directly contrary to the central premise of the Dodd-Frank Act amendments to TILA that led to the LO Comp rule, compensation is the most effective way to incentivize loan originator behavior.

The inability to tie compensation to the quality of a loan originator’s work on a given loan severely restricts the creditor’s ability to manage its employees and disincentivize future errors. Effectively, the creditor is left with two extreme options in response to the mistake: fire the loan originator, or pay them full commission despite the error. This binary choice does not serve the interests of consumers, creditors, or loan originators. Ultimately, greater accountability on the part of loan originators will incentivize them to reduce errors and consistently comply with regulatory requirements and company policy, leading to a safer and more transparent market for consumers.

Change Three: Lenders should be allowed to alter loan compensation in order to offer loans made under state and local housing finance agency (HFA) programs.  

TILA now states that “no mortgage originator shall receive from any person and no person shall pay to a mortgage originator, directly or indirectly, compensation that varies based on the terms of the loan (other than the amount of the principal).” The LO Comp Rule broadly prohibits compensation based on loan terms or proxies for loan terms, while providing a short list of expressly permissible compensation factors. In practice, this requirement is understood to forbid varying compensation for different loan types or products, including loans made under housing finance agency (HFA) programs.

However, the assistance provided through these programs is not without costs.  The robust underwriting, tax law-related paperwork, yield restrictions, and other program requirements make HFA loans more expensive to produce. HFAs also frequently cap lender compensation at levels below what a lender typically receives on a non-HFA loan. Covering these expenses is particularly difficult given that many HFA programs include limits on the interest rates, permissible compensation, and other fees that may be charged to borrowers. In the past, lenders would address this challenge by paying loan originators a smaller commission for an HFA loan than for a non-HFA loan. The inability to do so today reduces the ability of companies to offer HFA loans, particularly when producing these loans results in a loss. HFAs report that some lenders have left their programs and others have limited the volume of their participation. The Bureau should address this dilemma through an exemption in the LO Comp rule for HFA loans.

These loans encourage homeownership in a responsible and well-regulated manner. HFA programs provide participants with much-needed access to credit, along with housing counseling and financial education. HFA loans and partnerships with HFAs are important tools to ensure increased access to credit through Fannie Mae and Freddie Mac under the conservatorship of the Federal Housing Finance Agency. HFA programs are particularly important for first-time homebuyers and low- to moderate-income (“LMI”) families who are often underserved and encounter difficulty gaining access to credit elsewhere. In 2016, the latest year for which comprehensive data is available, the median borrower income for all HFA program loans was $49,598, 14 percent below the national median income for the year.

The inability to reduce loan originator compensation to offset HFA production costs under the current LO Comp Rule harms consumers by reducing the availability of these vital programs. Companies that wish to offer these loans do so at a loss. This has the effect of limiting the number of loans they can make and thereby reducing competition, and raising prices, for loans in LMI communities. The Bureau should address this by creating an exemption or alternative path to compliance loans made under local bond or HFA programs.

The rule’s rigidity makes HFA loans less available to consumers in LMI communities, a perverse result given that the rule was intended in part to protect LMI consumers from being steered into expensive loans with higher rates or fees. These unintended consequences need to be addressed. Similarly, CFPB has exempted loans directly originated by HFAs from the High-Cost mortgage rule and classified all HFAs as “small servicers” under its mortgage servicing rule, regardless of the size of their servicing portfolios.


The LO Comp Rule remains a top priority for MBA going into 2019. Industry and consumers would be better served if targeted changes were considered after five years of experience with the rule. We hope that Director Kraninger considers doing so at the beginning of her tenure.


The Latest Compliance Requirements for TRID and TRID 2.0

Although it had been several years since the housing crises, in the third quarter of 2015, residential mortgage backed securitizations were still sailing into headwinds as the private label securitization market was still a fraction of its former self. Lenders were finally getting a firm footing after the Dodd-Frank based regulatory changes effective starting with loan applications received January 10, 2014, most significantly introducing the Ability to Repay testing and modifying the federal high cost testing under the Home Ownership and Equity Protection Act.

Lenders were preparing for the TILA-RESPA Integrated Disclosure Rule (TRID), effective with loan applications as of October 3, 2015. The 1,888 pages of TRID meticulously rewrote the mortgage disclosure process with thoughtful detail, with the intention of making the mortgage origination process more transparent with easier to understand disclosures for consumers. The new disclosure requirements, also referred to as Know Before You Owe, were developed by the Consumer Financial Protection Bureau (CFPB) to help consumers understand the loan terms, loan features, and charges to facilitate shopping for loans they were considering. Two new disclosures, the Loan Estimate and Closing Disclosure, replaced the existing Good Faith Estimate, Initial TIL Disclosure, Final TIL Disclosure and Settlement Statement. Lenders were unaware of the severity of the storm coming over the horizon.

Despite the entirety of the mortgage origination industry focusing its efforts on defining the origination requirements of TRID, the secondary market was left to focus on defining the liability surrounding these new disclosure obligations that was not abundantly clear, specifically attempting to quantify the risk that the investor may face in the event that investor purchased a loan that contained a violation of TRID. The uncertainty surrounding the potential liability was compounded by the extreme scrutiny being placed on the disclosure timing and content that resulted in the perfect storm of compliance exceptions being identified on loans evaluated for secondary market acquisition.

The loans being reviewed were evaluated under a microscope with every misstep by the originating lender rendering an exception on the loan cited by the third-party review (TPR), firms as a material exception that required remediation, if remediation was available. It was more than a single rogue wave. The market liquidity for residential loans slowed to a standstill as aggregators, TPR firms, creditors, lawyers, and rating agencies tried to distinguish between significant compliance exceptions and others that could be included in securitizations. Anyone on the boat at that time was sure to put on their life jacket while bracing against the waves and winds that effectively stopped forward progress and threatened to capsize the market.

As a result, the Structured Finance Industry Group (SFIG), the trade association to the capital markets, through the SFIG RMBS 3.0 due Diligence, Data and Disclosure Workgroup took on the challenge of tying each and every provision of TRID to the specific liability provision of TILA with the primary goal of creating a uniform testing standard as a result of a consistent Truth-In-Lending Act liability interpretation according to their understanding of prevailing legal precedent and informal written guidance and webinars offered by the CFPB, as it applies to the Know Before You Owe/TILA RESPA Integrated Disclosure Rule.

This workgroup included individuals representing prominent law firms, TPR due diligence companies, rating agencies, issuers, and other industry participants. This SFIG effort resulted in the first version of the RMBS 3.0 TRID Compliance Review Scope© published on June 15, 2016, understanding that the conclusions set forth therein do not necessarily reflect how courts and regulators, including the CFPB, may view liability for TILA violations presently, or in the future. The first version of the SFIG TRID Compliance Review Scope proved to be the catalyst that the secondary market needed to confidently commence purchasing loans subject to TRID, providing much needed liquidity to the origination market. Since June of 2016, the rating agencies, TPR firms, and the capital market investors have confidently followed the SFIG TRID Compliance Review Scope effectively placing the private label securitization marketplace back on a strong footing.

On October 18, 2018, the SFIG RMBS 3.0 Due Diligence, Data and Disclosure Working Group published an updated version to the RMBS 3.0 TRID Compliance Review Scope© (v2) based on the Amendments to Federal Mortgage Disclosure Requirements under the Truth in Lending Act (Regulation Z) as published in the Federal Register [82 FR 37656] on August 11, 2017, (with an optional compliance date of October 10, 2017, and a mandatory compliance date of October 1, 2018), the updates related to the Black Hole that were effective June 1, 2018, and the Economic Growth, Regulatory Relief, and Consumer Protection Act enacted on May 24, 2018.

The RMBS 3.0 TRID Compliance Review Scope v2, as it reflects the amendments made by TRID 2.0, have included additional clarity. The guidance and clarifications made by the CFPB, with TRID 2.0 and the subsequent Black Hole Amendment, effectively reinforced the risk previously identified by the original RMBS 3.0 TRID Compliance Review Scope©, and now with 2.0, this reduced some testing requirements, reduced the materiality of certain tests, and the addition of a few tests. The impact of v2 will be fewer material compliance exceptions with the associated grading that would have otherwise, previously, prevented loans from being purchased by an investor, whereby the mortgage was targeted for a rated transaction.

SFIG, and its membership that participated in the drafting of the original RMBS 3.0 TRID Compliance Review Scope and in the updated v2 scope created a new standard in transparency in aiding the entire mortgage lending industry in translating and navigating the complicated mortgage lending regulatory regime with an eye toward building confidence in the secondary market ensuring that high quality mortgages can make their way into rated securitizations, thereby providing the necessary liquidity to the marketplace, and making homeownership a reality for more consumers.

Although over two years passed between the initial version of the SFIG RMBS 3.0 TRID Compliance Review Scope and the recently published v2, further refinements will be forthcoming in 2019, as SFIG continues the ongoing standardization of the TRID review scope while incorporating additional feedback from market participants, CFPB enforcement actions, regulatory clarifications, or caselaw. The v2 scope document is part of the ongoing output of the SFIG work groups to bring consistency to the due diligence reviews performed as part of securitization reviews.

In addition to working with market participants, SFIG is actively working directly with the CFPB to share the concerns and impediments to future securitizations based on regulatory uncertainty to attempt to obtain regulatory updates as well as informal guidance to ensure compliant loans are flowing into ongoing securitizations to foster a robust private label securitization for RMBS transactions.

There is a common reference regarding the calm before the storm, but the real calm comes after the storm has been faced. One would be remiss to think only smooth sailing lies ahead, but the winds have shifted and with the breeze at our backs and smooth water ahead, the SFIG workgroup strives to see the private label securitization of RMBS under full sail.


TRID 2.0 and Compliance Risk Mitigation Strategies

(As published in ABA Bank Compliance magazine in Janary 2019)

We’re now a few months past the mandatory effective date of “TRID 2.0,” and many mortgage lenders may be lulled into thinking it’s back to business as usual. However, with a regulatory initiative as massive as TRID, now is an ideal time to circle back and ensure your implementation efforts hit the mark, are in compliance, and that your disclosures match your actual policies and practice.

This article will review the TRID 2.0 amendments with an eye towards a few disclosure requirements that represent potential compliance risk. It will also discuss potential enhancements to TRID and future regulatory change. Could TRID 3.0 be on the horizon?

Setting the Stage

Compliance with the July 2017 amendments to the TILA-RESPA Integrated Disclosure (TRID) rule became mandatory on October 1, 2018. Dubbed TRID 2.0, these amendments provide technical corrections, clarifications and substantive changes to the original TRID rule that went into effect in October 2015.

At this juncture, much has been said and written about TRID 2.0 implementation. From a regulatory perspective, the Bureau of Consumer Financial Protection (“bureau”) itself has chimed in. The TRID 2.0 final rule contains a preamble that spans hundreds of pages and offers detailed discussion regarding compliance expectations. In addition, the bureau updated both the Small Entity Guide and the Guide to Forms to reflect the TRID 2.0 changes.
Clearly the industry is well-positioned to know “what” TRID compliance requires. Now the tide turns to managing the “how” and ensuring steps are taken to limit the risk of noncompliance.

TRID 2.0 Compliance Risk

Cooperative Units: TRID 2.0 provides much-needed clarification regarding mortgage loans secured by a cooperative unit. It creates a uniform rule whereby all closed-end consumer credit transactions (other than reverse mortgages) secured by a cooperative unit are covered—regardless of whether the unit is considered real or personal property under state law. Most TRID loans secured by a cooperative unit now trigger a Loan Estimate, a Closing Disclosure, the Special Information Booklet, and the record retention requirements.

Risk Management Considerations:  If you classify a cooperative unit as personal property for other purposes, ensure that your workflows and software systems are updated for TRID coverage. Also verify that staff is trained and understands the TRID impact on loans secured by a cooperative unit. Finally, ensure that you do not mix and match disclosures, for example, providing a non-TRID Good Faith Estimate or other early disclosure with a TRID Closing Disclosure.

Subordinate Lien Housing Assistance Loans: Currently, certain housing assistance loans may be exempt from TRID if six specific criteria are satisfied. TRID 2.0 modifies one of the criteria regarding costs payable by the consumer. The modification provides that transfer taxes, along with recording, application, and housing counseling fees, may be payable by the consumer. In addition, recording fees and transfer taxes are now excluded from the one percent cap on total costs payable by the consumer at consummation.

Risk Management Considerations:  If relying on an exemption from TRID, ensure that evidence of compliance is retained documenting the limit on the types of costs payable by the consumer and adherence to the cap on total costs payable by the consumer. This documentation should be retained in the loan file for examiner review and is not required to be provided to the consumer.

Also, verify that your organization has determined which Truth-in-Lending disclosures it will provide for such housing assistance loans. Although housing assistance loans may be exempt from TRID disclosures, they are nonetheless federally related mortgage loans that are otherwise covered by Regulation Z. This means that the “Fed Box” disclosures as outlined in section 1026.18 of Regulation Z would apply. In lieu of the “Fed Box” disclosures, lenders have the option of providing the TRID disclosures.

Right of Rescission: TRID 2.0 clarifies that with respect to the Closing Disclosure, only disclose the consumer’s name and mailing address under “Borrower.” The Commentary now specifically provides that the term “consumer” is limited to parties to whom the credit is offered or extended. While other parties to the transaction may have rescission rights because they’ve offered property as security for a loan, those rights do not create “borrower” status.

Risk Management Considerations:  Although not necessarily a new concept, ensure that staff is trained to understand the difference between a “borrower” and a party with   rescission rights only. Labeling a party with just rescission rights as a “borrower” may infer repayment obligations and could be deemed deceptive.

Remember that rescission provisions are independent of the TRID disclosure timing requirements. Those with the right of rescission have three business days to rescind the transaction, typically starting from the date the final Closing Disclosure is provided. Ensure your closing workflows and timelines reflect the three-day right of rescission.

Fees and Tolerances: TRID 2.0 clarifies that for purposes of meeting the “good faith” standard, certain charges paid to an affiliate of the creditor are an unlimited tolerance item. These certain charges are prepaid interest, property insurance premiums, amounts placed in impound accounts, charges paid to a third-party service provided selected by the consumer that were not included on the lender’s Written List of Providers, and charges for third-party services that are not required by the lender.  Note that while subject to unlimited tolerance standards, the above charges must be disclosed in good faith using the best information reasonably available.

In addition, TRID 2.0 addresses the tolerance threshold for a non-compliant Written List of Providers. TRID requires that the providers disclosed on the written list correspond to the required settlement services for which the consumer may shop, as disclosed on the Loan Estimate. If you fail to provide a compliant, Written List of Providers, fees that would have otherwise been in the “no tolerance” category because the borrower selected their own provider, will instead fall in the 10 percent category and, potentially, the zero percent category if paid to an affiliate.

Risk Management: Regularly train staff on the importance of disclosing fees that are legitimate, using the best information reasonably available. Tolerance violations may trigger costly cure provisions. In addition, failure to disclose fees and/or disclose a compliant, Written List of Providers could be deemed a Regulation Z violation.

Post Consummation Notices:  As required pursuant to other Regulation Z provisions, certain loans trigger a notice in connection with the cancellation of an escrow account and a disclosure regarding the partial payment acceptance policy in a mortgage loan transfer notice.  TRID 2.0 clarifies that if such post-consummation notices are required, they must be provided regardless of the loan application date. Previously, the post-consummation notices were only required for covered transactions if the application was received on or after October 3, 2015 (TRID effective date).

Risk Management Consideration:  Verify that workflows and documentation systems are updated to address the post-consummation notices for all covered loans, regardless of the application date.

Total of Payments Tolerance: TRID 2.0 now subjects the Total of Payments (TOP) disclosure to tolerance testing. The Total of Payments disclosure will be considered accurate if the amount disclosed is overstated or if the amount is understated by no more than $100. This is the same accuracy standard used in calculating and disclosing the finance charge.

Risk Management Consideration:  Ensure that you regularly perform tolerance testing. Understatements of the TOP that are greater than $100 violate Regulation Z and may extend the right of rescission time period.

Numerical Rounding: TRID 2.0 provides for a new requirement when rounding percentages.  Disclosures involving a percentage must be rounded at three decimal places, with all trailing zeroes to the right of the decimal place dropped. So, for example, a 2.4999% APR will be rounded to and disclosed as 2.5%, while a 7.000% APR will be disclosed as 7%. With respect to dollar amounts, several disclosures must be rounded to the nearest whole dollar. And when it comes to disclosures involving a zero amount, note that in the “final” column of the Cash to Close table, if the calculation yields a zero, that should be disclosed as a single digit—i.e. $0, not $0.00.  However, for prepaid interest in the “Other Costs” table—if no prepaid interest will be collected at consummation, the amount should be disclosed as “$0.00.”

Risk Management Consideration: It’s a picky point, but the rounding provisions do vary within the TRID rule and within the Loan Estimate versus the Closing Disclosure. Ensure that your systems are generating figures that reflect the proper rounding requirements, and periodically audit your calculations.

Tolerance Cures and Principal Curtailments: TRID 2.0 clarifies how principal curtailments (reductions) may be disclosed, and it allows for the disclosure of such a reduction instead of a lender credit when providing a tolerance cure. Such principal reductions may be disclosed in the Summaries of Transactions table on the standard Closing Disclosure or in the Payoffs and Payments table on the alternative Closing Disclosure. In either case, curing the violation with a principal reduction will trigger additional disclosures.

Risk Management Consideration: There is some confusion over whether a principal reduction should be disclosed on line K4 or K5-7 of the Summaries of Transactions table. This confusion stems from the fact that one regulatory provision covers both line K4 and K5-7, and it doesn’t specify use of one line over the other or prohibit the use of one line over the other. However, given the “adjustments” title prior to lines K5-7, it seems these lines should be limited to contractual adjustments between borrower and seller and principal reductions should be disclosed on line K4. Confirm with your compliance team and documentation provider how your organization will handle the principal reduction disclosure. .

Revised Disclosures: TRID 2.0 addresses both revised Loan Estimates and revised Closing Disclosures. With respect to the Loan Estimate, if you issue a revision after the consumer indicates an intent to proceed with the transaction, you do not need to complete the expiration of closing costs date and time fields on that revised Loan Estimate.

In addition, TRID 2.0 makes clear that a revised estimate may be provided merely for informational purposes versus a revised estimate used to reset fee tolerances. Note, however, that any revised Loan Estimate—whether to reset tolerances or for informational purposes—must update all fee disclosures using the best information reasonably available.

On the Closing Disclosure side, if the Closing Disclosure becomes inaccurate post‐closing, and the only reason for the inaccuracy is due to per diem interest, then a corrected Closing Disclosure is not required. If the Closing Disclosure is inaccurate post‐closing for reasons other than the per diem interest, and the per diem interest is likewise inaccurate, then the per diem must be accurately disclosed on the corrected Closing Disclosure.

Finally, in addition to TRID 2.0, the Bureau issued a final rule closing the “Black Hole” when using a Closing Disclosure to reset fees. Here’s the scenario: Once the initial Closing Disclosure has been issued, a revised Loan Estimate can’t be issued. The Closing Disclosure may be used to reset tolerances. However, the revision of fees must be done within three business days of learning of the event that triggered the revision.  Furthermore, a disclosure that revises fees must be provided no later than four business days prior to consummation. The “black hole” is the gap between the end of the three business days period after learning of a change event, and the start of the four business days period prior to consummation. To make a long story short, the  “Black Hole” final rule removes the four business days prior to consummation limitation when using a Closing Disclosure to reset tolerances.

Risk Management Consideration: If you provide an informational revised Loan Estimate, ensure that the entire revised estimate is updated. Also monitor change events and the impact on fees carefully. Ensure staff understands that a Closing Disclosure may be used to reset tolerances without regard to the four business days prior to consummation limitation. Resetting tolerances where permitted can help avoid implementing cure provisions and potential Regulation Z violations.

On the Horizon

While TRID 2.0 provided a fairly good clean-up of TRID 1.0, areas of uncertainty and contention remain. At the top of the list are construction loans. TRID 2.0 does provide much needed guidance regarding how to disclose a construction loan, including updates to Appendix D and a section dedicated to compliance in the Small Entity Guide. However, many in the industry continue to struggle with disclosure of such loans. Lenders are asking the Bureau for an exemption from TRID requirements for single-family residential construction loans. Citing consumer confusion and disclosure burden that is forcing many lenders out of the construction loan market, the industry is asking that at a minimum, the Bureau reduce liability enforcement.  From there, lenders hope the Bureau would consider adopting a more streamlined disclosure process whereby lenders can disclose basic information using a format of their choosing.

Along the lines of enforcement, the industry is also asking that the Bureau expand the ability to cure minor TRID errors. While TRID does provide measures for revising fees and resetting tolerances, many believe provisions to “fix” a problem are too burdensome and complex and must be simplified. The industry is also requesting an amendment that would extend the time to cure a violation after consummation. Such an extension would provide lenders more time to carefully review loan documentation post-consummation and make necessary corrections and refunds. While the Bureau may consider such requests, there is regulatory concern that additional cure provisions could reduce the incentive to comply with the TRID rule.
Needless to say, the industry hasn’t heard the last word on TRID as compliance requirements and expectations will continue to evolve. There is talk of repealing the Dodd-Frank Act altogether and thereby repealing TRID. Despite the new administration and a change in the bureau’s leadership, this might be wishful thinking at best. Institutions have dedicated significant resources toward TRID compliance, and who knows what might take its place if it were repealed. In the meantime, organizations should understand that compliance implementation is an ongoing process requiring continuous document review, policy and procedure audit and staff training. And despite political rumblings, institutions must stay the course and carefully manage TRID compliance and risk.



Sue Burt is a senior compliance consulting specialist with Wolters Kluwer. Her thorough knowledge of the bank regulatory environment is based on more than 30 years of industry experience. In her role with Wolters Kluwer, Burt uses her expertise to assist financial institutions in addressing compliance and other operational risk management issues.


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