Advancing to the end of the mortgage process and beyond closing, both the Loan Estimate and Closing Disclosure must be compliant (and defensible) to the end investor. Given the ambiguities within so many of the rules applicable to both forms, it is important to have a way to defend the programming logic used to define the output.
The CFPB left the grace period open-ended and most in the industry interpreted that to mean that it will last throughout the rest of 2015, at least. Unfortunately, as welcome as that grace period is, TRID remains a costly and complicated fix that has enormous implications for the whole industry..
“Bad letters damage the brand,” Katherine Porter says. “There’s a contagion effect of this. I think bad letters are unjust. They disproportionately harm the borrowers we need to help the most.” Read More