Did you know that "business day" under TRID is on a 24-hour cycle?
Just to clarify this point because there seem to be a lot of debates out there ...
What does it mean when they say we have three business days to deliver or place in the mail a Loan Estimate? Actually,it' s the same thing it would have meant under the old GFE regime ... but what is that?
Example
So here is our scenario:
You receive a mortgage application on Monday. That means you have until Thursday to deliver a Loan Estimate. Thursday rolls around and you're rushing to get the Loan Estimate out. A final check catches a last minute mistake- someone is working late to finish this. They work as fast as they can, but they are not able to drop the Loan Estimate at the Post Office until 9:00 pm (after your normal business hours and after the Post Office was closed).
Question
In this scenario, are you out of compliance with the requirement to deliver the LE within 3 days of "application"?
Answer
No. This is compliant. Even though this was dropped at the Post Office after hours (after the lender and USPS were closed), this still counts as the third business day because "business day" is defined under these regs. as being on a 24-hour cycle. This would have been good as long as it was left with the Post Office at 11:59 or sooner. Side Note - So if you get an application at 11:59 on Monday night, then you better make sure the Loan Estimate is out by Thursday, not Friday!
Proof another matter ...
While the above is compliant with the 3-day rule, proving this is another matter - i.e., proving that you dropped the Loan Estimate at the Post Office before 11:59 pm and not anytime after. If you deposit a letter with the USPS on Monday, it won't necessarily be postmarked that same day. And how would you keep evidence of the postmark anyway? The answer is that we're probably over-thinking this - the Loan Estimate should be dated on the day it was delivered, and this should be described in written procedures. You may have internal logs to evidence delivery to the Post Office. That should be enough to shift the burden to the regulator or consumer (if it ever comes up) to make them have to prove it was not delivered on time.
In Other News:
Boy, how bad is your customer service if third party companies are popping up for customers to pay them to deal with you on their behalf? That's what's happening with Comcast - you can pay a company called AirPaper to cancel your Comcast service for you. Actually sounds like a bargain too.
Hoping Congress will pass some TRID regulatory relief? Hope springs eternal, I guess, but it doesn't appear likely - the White House released a statement saying President Obama would veto such a bill.
And let the 'dad jokes' begin - "Velcro, what a rip-off!"
How would you explain what Reg. D does? Reg. D is a rule that basically prevents people from turning savings accounts into checking acccounts. No reserve is required for savings accounts, but there is a 10% reserve required for checking accounts (obviously, we're expecting people to be using a checking account more). So what does Reg. D do to limit this activity? Here's a great chart that explains it all.
Does your company have a good online presence? Is connecting with consumers online the next step, or something already necessary? How do you even establish a good online brand? Here are some "best practices" for building an online/social media presence from David Horsager's book The Trust Edge:
Be simple and clear.
Be informative.
Make it easy to connect with you.
Show real people.
Be a member of credible groups and show their logo.
Show your history.
Use true client testimonials.
Include a FAQ section.
Respond quickly.
Confirm it.
Keep in touch.
Avoid too much advertising.
Update often.
Have and display a strong privacy policy.
Offer a generous return policy.
"Only those who have learned the power of sincere and selfless contribution experience life's deepest joy: true fulfillment."
- Tony Robbins
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**These are our opinions. We're not authorized, or willing, to express those of others.**