At the Compliance Academy last week, Kelly mentioned (if I heard her correctly) that you should not select that the rate was locked on TRID disclosures unless you have a written rate lock agreement. Can you provide additional guidance on this topic?
I also need guidance on 45 day flood notices. Again if I heard correctly, Jack said that these letters should be sent after the policy expires giving the customer 45 days to renew their policy. However, we have been providing our notices 45 days prior to the expiration of the policy. I’m assuming I need to have loan operations correct their policies and procedures, but I would like additional guidance before doing so.