MORTGAGE GUIDELINES: TRID & MARKETING DON’T LET TRID DETERMINE YOUR LEVEL OF SUCCESS SEPTEMBER 10, 2015
Agenda
Age
ncie
s CFPB
FTC
FCC
National Credit Reporting Agencies Re
gula
tions
TRID
TILA
RESPA
FCRA
Dodd Frank Wall Street Reform
Consumer Financial Protection Act
What is the FTC?
Federal Trade Commission •Independent Agency of US Government •1914: Established by Federal Trade Commission
Act • Investigates & prevents deceptive trade
practices (false advertising) •1990s: Fraud sweep of telemarketing agencies
What is the FCC?
Federal Communications Commission • Independent Agency of US Government • 1934: Established by Communications Commission Act • Regulates interstate communications by radio, TV, wire,
satellite, telecom, & cable (protection of consumer privacy)
• Funded by regulatory fees • 1996: Telecommunications Act – loosening the rules of the
Communications Act • 2006: FTC faced scrutiny NSA wire taping.
What is the FCRA?
Federal Credit Reporting Act •1970: US Federal Law for consumer credit rights •Creditors must report complete & accurate
information to credit reporting agencies •Negative information may only be kept for 7 yrs. •2003: Fair & Accurate Credit Transactions Act –
consumers entitled to one free credit report/yr.
What is TILA?
Truth in Lending Act • 1968: US Federal Law • Promote informed use of consumer
credit • Requires uniform disclosure of fees • Does not regulate the fees
What is RESPA?
Real Estate Settlement Procedures Act • 1974: Passed by US Congress • Created to stop kickbacks between builders,
lenders, realtors & lending companies • Requires clear statement of fees due to
promote competition & drive prices down
CFPB
Most Pressing Concerns
Student Loans
Mortgages
Credit Cards
CFPB IMPACT ON: FCC, FTC, FCRA, TILA, RESPA, AND NOW TRID
July 2011
TILA & RESPA
Authority transferred to CFPB
January 2012
MOU
Streamline Regulatory Efforts
November 2012
FTC & CFPB
Regulation N
November 2014
FCC
$10M Fine
March 2015
FTC & CFPB
Coordinate efforts
October 2015
TRID
3 Day Rule
Similarities: FCC, FTC, FCRA
FCC
FTC
FCRA
All formed under US Government
Enacted to protect consumers from fraudulent & predatory business & marketing practices
All funded by US Government
Work same way in their regulation: Someone must complain for
anything to be done
Dodd Frank Wall Street Reform
Consumer Protection Act
Housed in the Federal Reserve
New standards Protect
consumers from predatory
lending
Fining companies out of compliance
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Integrated Disclosures
Prior Forms Required by TILA
Prior Forms Required by RESPA
Integrated Disclosure
Required by TILA-RESPA Rule
Application Initial TILA GFE Loan Estimate
Closing Final TILA Loan Estimate Closing Disclosure
Dodd-Frank Reform required TILA & RESPA to integrate their disclosures
What is TRID?
The purpose of TRID is to assure consumers obtain the necessary information needed when signing lending documents
Image Source: www.thetruthaboutmortgage.com
Rules & Regulations. A Process For Protecting Consumer Data
FCRA, TCPA, TILA, RESPA, & TRID
Ignorance doesn’t hold up in court
Tech company security processes not disclosed
Government working on laws requiring disclosure of all processes of securing data
Image Source: www.um.edu.mt
Generate More Business
Use your tools to generate
more business
You have access to specific
information to target
consumers
Market and generate
new business
Credit Data
Must lend money to consumers in order to use credit data
Rules & regulations: to ensure consumers don’t receive offers they don’t quality for
Lenders therefore market to people who are pre-qualified
Image Source: www.perc.net
3 Day Rule
3 D
ay R
ule
Lend
ing
Estim
ates
Doc
umen
t Sig
ning
Lock
in R
ate
for
Borro
wer
Lose
Bus
ines
s
Dec
reas
e in
Loy
alty
Rate
s Cha
nge
Con
stan
tly
Credit Data & Qualified Borrowers
Credit Data • Use for marketing
efforts • Has strict guidelines • Guidelines match
TRID • Ensure borrowers
qualify
Image Source: www.mortgagebattlecall.com
The Marketer’s Job Keep you, the lender,
aware of what’s available to you
Acquire more business
Compliant Marketing Firm
Help you stay compliant with your guidelines
Help you hit your growth goals
Image Source: www.realestatemarketingblob.org
Pre-Qualified Borrowers
Loan Amount
Revolving Debt
Amount Income LTV
Loan Origination
Date Credit Score
Credit to Debt Ratio
Personalized your Marketing using Credit Data
Image Source: www.chicagorealestatedude.com
Pre-Qualified Borrowers Personalize your campaigns Not Wasting Everyone’s Time Shows You Care Instilling Trust & Loyalty Acquire More Business Stay in Compliance Marketing is Compliant Compliance with Own Guidelines Hitting Growth Goals
QUESTIONS TAGQUEST Caleb Guillory 866-376-5540 www.tagquest.com
Use TRID and Credit Data to Help you Build your Business
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