Pub. 18 2021 Issue 2

22 THE BLACK AND WHITE OF TRID TIMING By John Berteau, Associate General Counsel, Compliance Alliance T here are so many ways to violate TRID. Mastering the content requirements (knowing what to put where) is difficult for even the most seasoned compliance professional and is the source of numerous violations. Conquering the timing requirements (knowing when to give what) seems to be a much easier assignment, but it too causes numerous violations. When it comes to what information to include in disclosures and in which section, there are many gray areas, too much, in fact. However, the regulations are a lot more black and white when it comes to giving the disclosures. Let’s face it, TRID is difficult. First, even the name is challenging: TRID is an acronymmade up of other acronyms. TRID is short for TILA-RESPA Integrated Disclosures. TILA is an acronym for the Truth in Lending Act, and RESPA is an The Loan Estimate is a reliable estimate of costs provided early in the process to loan applicants to allow them to shop around for the best loan. The Closing Disclosure is a detailed listing of costs given just before closing to let the applicant know the confirmed cost of credit.