TRID (TILA/Respa Integrated Disclosure) is an acronym that we in the settlement services industry are using to describe a whole set of new rules we must all comply with as of October 3, 2015. In actual fact this means that any loan application taken on or after October 3 is affected by these new rules.
Of particular interest to consumers and to Realtors is the use of the new CD (Consumer Disclosure) which is to be prepared, for the most part, by the LENDERS not by the Title Agent. This is a totally new concept for all of us and requires that we all work together in concert to ensure that the lender has everything that they need from all of us to enable the lender to meet delivery time lines on the CD. (CD to consumer 3 business days in advance of closing)
So, what does that mean to you, the Abstractor?
- Your turn times are going to be reduced and
- Your payment time is going to be extended
Because the lender needs everything from the title agent not less than 10 days prior to closing in order for them to meet the 3 day delivery rule, title agents, Realtors, abstractors and others must work together as a team to get all of the required information together as quickly as possible. This means that you as an abstractor will likely be seeing shorter turn times.
In addition because of the new rules lenders are asking that Realtors write 60 day contracts rather than 45 day contracts that means that abstractors will be seeing their payment later than what they may currently be accustomed to.
AND, we must now provide invoices for all fees being charged on the CD for services rendered for such things as abstracts and copies. I did see one post in the forums today regarding providing invoices for copies from the courthouse. I realize that this is a royal PIA, but it is part of the new rules to insure that the consumer is able to shop loans and total closing costs prior to commitment to a loan. Lenders are requiring that we present them with all invoices to be charged to the consumer including invoices for title search, copies, judgment searches etc. Many title agents are lumping these fees into their total settlement fee so they may not be looking for individual invoices, but, in the instance where we need lots of copies out of the court file, for instance in a foreclosure situation, those fees are generally charged on a separate line item. If they are charged on a separate line item, we MUST have an invoice to prove the cost.
Working together we will all adjust to the new rules. For the first few months we may all find that things feel a little more burdensome and difficult but I think that after the initial shock we will all come to like the new way of conducting business.