Pub. 1 2021 Issue 1

24 | The Show-Me Banker Magazine COMMUNITY BANKERS FOR COMPLIANCE Construction Loan Compliance Ever since the advent of the TILA-RESPA Integrated Disclosures (TRID) a few years ago, banks have struggled with disclosing a construction or construction/permanent loan. A major part of the problem has been the inability of the Consumer Financial Protection Bureau to clearly articulate the TRID requirements. This inability has created problems for bankers, loan software companies, auditors and consultants, regulators, and most importantly, consumers. And while we have a clearer picture now, there still are questions that remain unanswered. This seminar will discuss the variety of legal ways to structure and disclose construction and construction/permanent loans, and the impact those decisions may have on your institution and consumers. After discussing the construction product and disclosure possibilities, we will then take those possibilities and apply them to the TRID disclosures themselves. For the TRID portion of the seminar, we will be focusing on two elements. The first will be the timing of the Loan Estimate and Closing Disclosure in a construction or construction/permanent loan. This discussion will be relatively brief, as we discussed general TRID timing requirements during our 2020 CBC presentations. The balance of the TRID presentation will focus on the TRID forms themselves, discussing the options available and the re- quirements to complete the Loan Estimate and Closing Disclosure. As with the timing discussion, we will limit our discussion to those areas which carry the most TRID risk for construction and construction/permanent loans. The teaching manual will only include the information that will be discussed in the seminar. A more complete set of TRID manuals, covering all TRID requirements, will be available to attendees via the web. The seminar will conclude with a demonstration of the relatively new FFIEC APR computational software and how to use it to validate APRs for construction and construction/permanent loans. The subjects for the regulatory update will be determined by circumstances and releases from the various agencies. DATE, LOCATION, HOTEL INFORMATION March 2, 2021 MIBA’s Office 106 E. High Street Jefferson City, Missouri, 65101 Hotel Accommodations: The DoubleTree Hotel 422 Monroe Street Jefferson City, Missouri, 65101 Phone No.: 573.636.5101 Light Breakfast & Registration: 8:30 a.m. Seminar: 9:00 a.m. ‐ approx. 4:00 p.m. Future Presentations During the second quarter, we will be covering Regulation F — Fair Debt Collection Practices Act. Released at the end of October, it will be effective one year after publication in the Federal Register (proba- bly November 2021). It will not have major impacts on many banks FOR NOW, but the CFPB has stated the ultimate goal is for all bank collection efforts to be made subject to the rule, so we will discuss the short and long-term ramifications of this new regulation. Other topics to be covered in the second quarter 2021 have not been determined. Subjects for future seminars will be shaped by regu- latory events as they unfold. The CBC quarterly com- pliance program remains committed to providing as much up-to-the- minute information as possible. The program will closely monitor releases from the CFPB and other agencies to assure that you have the most up- to-date and accurate information possible.