Here are four tips mortgage companies should
consider to ensure they get timely and accurate
fees to meet the requirements of TRID.
1. Only work with compliant vendors. Make
sure vendors have completed certifications or
audits that demonstrate their commitment to
secure processes, such as SSAE 16 Type II. Meeting such a standard will ensure a vendor’s services and controls have been tested and that its
data is securely maintained and controlled.
4. Standardize how you charge fees. In most
cases, a credit-report fee is $18, for example, but if
a processor ends up needing a credit supplement
or credit update for a loan, the company would
end up paying the incremental cost, unless it had
already disclosed the cost. To standardize fees,
some companies disclose a higher credit report
fee to include possible contingencies.
Mortgage companies should not wait until the
last minute to handle TRID-related disclosures.
Fortunately, most LOS providers have done a
great job of interpreting the many facets of TRID
and have provided the necessary alerts to signify
redisclosure requirements. An important question remains, however. Who is responsible for
managing these alerts? Is it the loan originators,
the processors or the disclosure desk? Without
a clearly defined workflow and communication
process, these alerts can go unheeded, which
will result in compliance issues.
The first step toward addressing these questions, obviously, is to define the workflow. The
workflow should clearly spell out the responsibilities of every team member. It also should
have built-in redundancies so that nothing gets
overlooked or lost, and it should include an outline for management oversight.
Josh Friend is founder and CEO of InSellerate, a specialized customer
relationship management system that enables lenders to instantly connect
to leads, manage their sales team in real time and build strong, long-term
customer relationships through automated marketing campaigns.
Reach Friend at email@example.com.
Of course, having a well-defined workflow will
not guarantee success if it is not followed consistently, nor if it cannot prevent missed deadlines, absences or other obstacles. Therefore, the
second step is to use available technology to automate the workflow.
Fortunately, emerging technologies exist
that can automate workflow while minimizing
risk and exposure. An LOS could, for example,
send an alert when a change of circumstance
requires a disclosure. If a lead-management
system is properly integrated with the LOS, it
could simultaneously send a notification to
the disclosures clerk, processor and manager and assign the right person to address that
change of circumstance. If no one addresses
the change, a manager could then be notified
to take action.
By automating the escalation of a change in
this way, mortgage companies not only achieve
compliance, they also improve the borrower experience by being able to respond quickly, preventing any unnecessary delays on the way to
the closing table.
n n n
The mortgage process will never be perfect, but
as the immortal Vince Lombardi once said, “if we
chase perfection we can catch excellence.” Proof
of these words can be found in the way technology has already made selling loans significantly
more accurate and efficient. In other words, automation hasn’t let us down yet. When it comes
to current and future TRID revisions, there’s no
reason to think it will. n
2. Choose vendors committed to improving
accuracy and efficiency. Vendors should be
able to show they are committed to improving
their technology and internal systems, such as
providing technology to automate fees and
changes to the loan file.
3. Fully understand your own workflows. Be
willing to automate the pieces of the process
that make sense. A mortgage company should
be able to set up automated alerts for loan-amount changes or program changes within
their loan origination systems (LOSs). Further,
they should be able to run daily reports, manage
any changes of circumstance and receive automated alerts when redisclosures are needed.
Proper LOS implementation and configuration
and staff training are critical.
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