TRID Compliance Exams for Lenders
The Office of the Comptroller of the Currency has notified lenders that it will soon begin its initial examinations of compliance with the TRID rules launched October 3, 2015.
The examination will consist of reviewing an organization’s overall effort and management system as it pertains to the implementation of TRID. While a grace period has been approved, the timeframe has not been defined or formalized. The OCC will review the organization’s dedication to fully complying with the new rules and will base their decisions from there. They have said the scope of the change will be taken into consideration when examining companies but that a “good faith effort” must have been taken in order for the OCC to recognize the organization as being compliant.
These examinations are incredibly important because not only will it give lenders a better understanding of where they are in complying with the new rules but also it is the first major “test” the lenders and the industry will face since the official implementation. The transition to these new rules appeared to go over smoothly but these examinations will give executives a clearer view of exactly where they stand, what improvements need to be made, and how they can continue to or improve upon service to consumers.