Fannie Mae and Freddie Mac yesterday issued letters to the mortgage lenders they work with explaining their posture toward compliance with the TILA-RESPA integrated disclosures, which went into effect for new mortgage applications on Saturday.
Fannie and Freddie said they are “aware that some lenders continue to address the implementation of TRID’s technical requirements. In recognition of this, until further notice, [the GSEs]will not conduct routine post-purchase loan file reviews for technical compliance with TRID.” After this “transitional period,” the GSEs said, they will revisit “whether to begin such reviews for technical compliance.”
Instead, Fannie and Freddie will “evaluate whether the correct forms were used in connection with the origination of a mortgage loan,” which they identified with a good-faith effort to comply. “[F]ailure to use a TRID-required form will be deemed a violation of the good faith efforts standard and will render the mortgage loan subject to all contractual remedies, including repurchase,” they said.