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Since the TRID revisions are not mandatory until 10/1/18, but can be implemented early, after 10/10/17, would it be acceptable to implement some but not all of the changes on 1010/17? For example, would we be permitted to implement the change to allow the 10% category limit to include in aggregate an item that was charged at closing even if it was omitted from the LE on 10/10/17, but not update our Required Service Provider List to stated the actual services required until 10/1/18?
Thank you.The CFPB’s executive summary and the final rule tells us you can make some of the changes on the effective date if you choose to do so, but compliance is mandatory on 10-1-18. It states:
“Beginning on the 2017 Rule’s effective date and for transactions for which a
creditor or mortgage broker receives an application prior to October 1, 2018, a person can comply with the 2017 Rule, but is not required to do so. Generally, during this optional compliance period, a person may comply with the changes set forth in the 2017 Rule all at one time or phase in the changes over time (even within the course of a transaction). Notwithstanding this flexibility, a person cannot phase in the 2017 Rule in a way that would violate provisions of Regulation Z that are not being changed. ” (e.g. issuing a GFE and then CD).With that in mind, if you are going to begin to take advantages of some of the changes that will benefit the FI I would also ensure the disclosures are updated to benefit the consumer (making them as informed as possible). on the shopping list, I assume you are already disclosing services that you require and for which you allow the consumer to shop, but if there are changes you would need to make then I would recommend you make those in conjunction with implementing the clarifying comments regarding the 10% tolerance bucket. In addition, it might be easier to implement these changes incrementally rather than all on the mandatory compliance date.
Please let us know if you have additional questions.
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