Market and some of the unintended consequences related to its

Overview

The purpose of this session is to provide an overview of the TILA-RESPA

Integrated Disclosure Rule, ¡°TRID¡±, from a Secondary Market Perspective.

This session will discuss the implications that TRID has had on the secondary

market and some of the unintended consequences related to its

implementation.

Topics include Investors Considerations, TRID Assignee Liability, Compliance

Issues, and Cures/Remediation of Errors.

Presenter: Scott McNulla

SVP Regulatory Compliance

American Mortgage Consultants, ¡°AMC¡±

AMC is a leading nationwide due diligence and consulting services provider

with offices in New York, Chicago, Denver, Dallas, and Tampa.

AMC does not provide legal advice or issue legal opinions. Please contact your legal counsel for legal advice

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Table of Contents

1.

TRID Background

2.

Investor Concerns (Secondary Market Considerations)

3.

TRID Assignee Liability

4.

Current TRID Compliance

5.

Cures / Remediations

6.

CFPB Proposed TRID Rule Clarifications

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Background

For over 30 years, lenders were required to provide 3 disclosures to

consumers applying for a mortgage. The Good Faith Estimate (GFE) the Truth

in Lending (TIL) disclosure and the HUD-1 Settlement Statement

The forms were required under 2 different statutes, Real Estate Settlement

Procedures Act (RESPA), and Truth in Lending Act (TILA), and the forms

contained overlapping information with inconsistent language

The Dodd-Frank Wall Street Reform and Consumer Protection Act (DoddFrank Act) directed the Consumer Financial Protection Bureau (CFPB) to

integrate the 2 disclosures (both at application and closing) into 1 more

meaningful and consumer-friendly form.

The CFPB¡¯s new rule was introduced as the TILA-RESPA Integrated Disclosures

Rule, or ¡°TRID¡± also referred to as Know Before you Owe, or ¡°KBYO¡±.

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Background Timeline

July 21, 2010 - Dodd-Frank Wall Street Reform and Consumer Protection Act

July 9, 2012 - Proposal of the new rule

November 6, 2012 - The Comment period on the proposed rule closes

November 20, 2013 - The final rule is published

January 20, 2015 - Amendments to the rule are issued

July 21, 2015 - New Effective Date Announced

July 28, 2016 - Proposal of Amendments to the rule

October 18, 2016 - Comment period closes

TBD - Amendments to the rule have not yet been issued

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