Find all your TRID Resources HERE – https://www.bankerscompliance.com/regulations-we-cover/tila-respa-integrated-disclosures/
Well, hello from South Dakota. My name is Kevin Edwards. I am a consultant with Bankers Compliance Consulting. And I’m on my way to visit a client and stopped off here to take in some of the beautiful scenery, and got to thinking about TRID of all things. I mean, it’s one of those topics that always seems to be going across my mind. It’s an occupational hazard. But one of the sticky areas, particularly for banks that have either a lot of ag customers or a big commercial book is identifying all of your TRID loans. You see, every once in a while, you have a customer who is maybe not a normal consumer customer, but they’re coming in and let’s say they want to get that Cadillac to drive to town. And they want to secure it with some very rural land that is not developed, something like what I’ve got going on behind me.
Even though this is a national park, so nobody better be securing any loans with national park land. But let’s say it’s something similar to this and they want to get that Cadillac. Is that a TRID loan? And the answer is yes, you have a consumer purpose loan, presuming that it’s closed end, but it’s secured by real estate. And it doesn’t matter that it’s rural or that it’s undeveloped, you still have a TRID loan. Now this is an area that oftentimes can be confusing, particularly for bankers who are either commercial or ag lenders who don’t normally have to deal with TRID. They oftentimes think that those are the disclosures that have to be filled out when you have a mortgage loan or something along those lines. So keep in mind that no matter how rural or beautiful the land securing the loan is, if it’s consumer purpose, then you’re playing the TRID game.