We don’t have any further intelligence on whether or not FHA is going to start to include TRID compliance as part of QC reviews on April 16. My suspicion is when FHA issued this guidance, it may have thought six months would be a sufficient amount of time for implementation. And what we have seen through the reviews and percentages we’re getting from QC vendors and what’s been going on in the marketplace, perhaps companies aren’t adjusting as quickly as FHA thought they would. It’s possible, but we’re not aware of any guidance or rumblings from FHA saying they are going to somehow extend this period.
The only thing I would note which is not FHA specific, is that Fannie Mae put out guidance in February, which I’m not sure if people picked up on or not, because it really related to enforcement of violations of the with compliance of law rep and warrant and wasn’t TRID specific. But if you haven’t seen it, you should look. It’s section A3-201 of the Seller Guide, which was updated on February 23. It talks about how Fannie can enforce a remedy for all lender violations applicable to federal, state, and local laws that have a material impact on Fannie. So, we have yet to see, given that this has been in place for approximately a month, what if anything it means in connection with prior guidance that said Fannie wouldn’t really look into TRID compliance issues other than making sure you were using the right form and making sure nothing you were doing would somehow impact their ability to enforce the mortgage or note. But it’s something to be aware and on the lookout for.
Answered By: Amanda Raines Lawrence