March 18, 2016 Alert - SFIG members work to standardize compliance review of new TRID rules

Yesterday evening, March 17th, participants of SFIG’s Due Diligence and Data Disclosure work stream under the RMBS 3.0 initiative, particularly the third-party review firms, distributed a draft proposal for comment regarding a standardized approach to the scope of review for exceptions to TRID rules, consistent exception grading, and consistent remediation considerations.

Over the next few weeks, SFIG members expect to vet the proposal through the committee process and incorporate the final product into the RMBS 3.0 Green Papers.

It is important to note that this project will not supplant SFIG’s efforts to pursue a Consumer Financial Protection Bureau (“CFPB”) resolution to the current uncertainty related to TRID exceptions.

Specifically, this draft assumes TRID is interpreted by regulators and courts in accordance with the principles of liability set forth in a December 29, 2015 letter from Richard Cordray, the Director of the CFPB. The proposed exception grading and remediation does not necessarily reflect how courts and regulators, including the CFPB, may view liability for TRID violations in the future.

Therefore, SFIG’s draft compliance review proposal is being considered and pursued as a concurrent initiative to address the immediate market concerns while SFIG and its members continue to pursue the long term goal to resolve the uncertainty with the CFPB.

SFIG is committed to continuing to work with its membership, other trade associations, congressional representatives, and the CFPB to resolve the continued uncertainty around exceptions to the TRID rules and the manner in which they can be remediated.

To view SFIG’s RMBS 3.0 Green Papers, please click here. Please contact daniel.goodwin@sfindustry.org with questions regarding TRID.

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