TRID PREPAREDNESS CHECKLIST
Action Item
Target
Completion
Date
Date
Completed
Open Issues / Comments
1. Establish an implementation committee
to build collaboration and consensus
around changes to processes and
workflows, as well as implementation of
systems, policies and procedures and
monitoring for progress and compliance
up to and after the October 3, 2015
implementation date.

2. Policies and procedures updated

3. Establish scripts for MLOs to
communicate with consumers and
realtors at the outset of the application
process to set realistic expectations for
the flow of information,
communications and timing of
disclosures and closings.

4. MLOs, underwriters and processors
trained

5. If the institution provides estimates of
closing costs in advance of issuing a
Loan Estimate, ensure that any such
estimates include the required language
that such fees may change and that the
document does not resemble the Loan
Estimate.

ument title]
Action Item
Target
Completion
Date
Date
Completed
Open Issues / Comments
6. Review any checklists or letters provided
to consumers at the outset of the
application process to ensure that there
is no indication of verification of
application information being required
prior to delivery of the Loan Estimate.

7. Ensure that no fees other than credit
report fees are being collected prior to
issuing the Loan Estimate and receiving
Intent to Proceed from the consumer.
Clearly communicate to staff that they
cannot collect post-dated checks or
credit card numbers for any fees prior to
the delivery of the Loan Estimate and
confirmation of consumer’s intent to
proceed, as such activity constitutes
“imposing a fee”, even if the check is
not cashed or the card charged until
after the Loan Estimate and Intent to
Proceed.

8. Checklists developed for pre-close and
post-close compliance reviews

9. System and software updates in place
and implemented

10. Products and policies developed within
LOS (If the institution is no using an
automated LOS, define each product
description to ensure it is consistently correctly
described on disclosures.)

11. Standard fees defined and categorized to
ensure sufficient, consistent descriptions
are being used and the fees are correctly
listed in the appropriate sections of the
disclosures.

12. Lists of service providers developed and
affiliate providers identified to correctly
determine tolerance categories. Define
services for which consumers will be
permitted to shop.

www.sterlingcompliancellc.com
alucas@sterlingcompliancellc.com | 412.855.7740
lzigo@sterlingcompliancellc.com | 724.813.2354
ument title]
Action Item
Target
Completion
Date
Date
Completed
Open Issues / Comments
13. Determine how the institution will
identify 0% and 10% tolerance items
and ultimately reconcile for
determination of any required cure.
Most loan operating systems will have
this capability, but it should be tested. If
you’re not using an LOS platform for
disclosures, you will need to have a way
to reconcile the tolerances and retain the
documentation with the loan file.

14. Discussions held with settlement agents
used by the institution to establish
logistics around ongoing
communications throughout the process
as well as the closing process, including
providing and reviewing disclosures and
any revisions.

15. Transactions tested within LOS to
validate accuracy of disclosures. This
should include a purchase and refinance
transaction for each product type (i.e.,
fixed rate, ARM, construction, home
equity loan, etc.). Also test for fee
increases beyond tolerance to ensure
required cures are identified and the
credits are reflected on the Closing
Disclosure.

16. Determine where changes to process
workflows between MLO, processors,
underwriters, closing agents need to be
adjusted to ensure disclosures are being
issued within required timeframes
throughout the process, including any
revisions resulting from changed
circumstances. Consider centralizing
certain aspects that may not currently be
centralized to maintain reasonable
control of the process.

17. Evaluate Rate Lock Agreements to
determine whether the lock period is
appropriate given the likelihood of
longer turnaround times for closings
under TRID.

www.sterlingcompliancellc.com
alucas@sterlingcompliancellc.com | 412.855.7740
lzigo@sterlingcompliancellc.com | 724.813.2354
ument title]
Action Item
Target
Completion
Date
Date
Completed
Open Issues / Comments
18. Determine how you will document
delivery and receipt of the Loan
Estimate and Closing Disclosure to
evidence compliance with timing
requirements. If using multiple delivery
channels for disclosures (US Mail, in
person, electronic), ensure staff
understand the timing rules, including
the “mailbox” rule and how to
document the file for the method of
delivery, dates sent and acknowledged
receipt by the consumer.

19. If moving to electronic delivery of
disclosures, verify that the process
complies with the E-Sign Act for
documenting consumer consent, ability
to opt out, acknowledgement of receipt,
and tracking same within the system.
Provide training, as necessary, to ensure
staff understands E-Sign requirements.

20. Define transactions not covered by
TRID for which a GFE and/or HUD
may still be required.

21. Determine applicable state laws for
determining:
a. Date of Consummation
b. Liability after foreclosure

22. If loan numbers are not assigned at the
outset, determine what Loan ID will be
used on the Loan Estimate and carried
through to the Closing Disclosure, and
how that will be assigned.

23. If your institution is not currently using
a LOS platform, consider options versus
potential risk of non-compliance with
manual processes and documentation.

24. Establish independent review or audit
procedures for TRID compliance, both
during testing phase and postimplementation.

www.sterlingcompliancellc.com
alucas@sterlingcompliancellc.com | 412.855.7740
lzigo@sterlingcompliancellc.com | 724.813.2354
ument title]
Action Item
Target
Completion
Date
Date
Completed
Open Issues / Comments
25. Document and track all non-compliance
and process difficulties for appropriate
resolution.

26. Establish periodic reporting to
Management and Board of status of
implementation, issues arising from
independent reviews or audits and
corrective actions taken.

www.sterlingcompliancellc.com
alucas@sterlingcompliancellc.com | 412.855.7740
lzigo@sterlingcompliancellc.com | 724.813.2354