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Case Study

Regulatory Upheavals Coming? No Problem

Guild Mortgage Co. used custom training and a new LMS to prepare for a massive regulatory change and establish themselves as an industry leader.

change management, regulatory upheaval, complianceIn the mortgage industry the acronym TRID will send shivers down the straightest spine, and rightfully so. TRID, or TILA-RESPA Integrated Disclosure, replaces the Truth-in-Lending Disclosure and Good Faith Estimate regulation for mortgage loans, and it is driving sweeping change across the home loan environment.

TRID was enacted to better control predatory lending practices in the banking industry and to create greater transparency for borrowers, both of which were badly needed. But adapting to the new regulation was incredibly disruptive, said Catherine Blocker, executive vice president of operations for Guild Mortgage Co. in San Diego, one of the largest independent mortgage banking companies in the United States.

“Getting ready for TRID required a major overhaul of all of our systems and procedures,” she explained. “It was the single biggest regulatory change to happen since we’ve been in business.”

The regulation set new requirements for reporting, waiting periods, liability rules and other elements of the loan process that impacted every aspect of how the company works with customers and with its business partners. To prepare for the change, Guild had to update all of its technology and workflow processes, and develop extensive training for the company’s 3,300 national employees — before the rule went live on Oct. 3, 2015. A final draft of the rule was released Dec. 31, 2013, giving the mortgage industry less than two years to prepare.

One Line at a Time

In January 2014, a team of Guild compliance and operations experts sat down to figure out exactly what the rule said and how it would impact their operations. “We spent four hours a day for weeks going through the regulation,” said Erin Langevin, vice president of national sales operations.

Combing through each line, they identified what parts of the rule would impact the business and employees’ workflow, then organized them into three training buckets: what employees need to know about the rule, how it will impact daily tasks, and what changes are out of their control but still need to be managed. The third category had to do with tasks relegated to partner agencies. For example, real estate agents used to be responsible for delivering a final cost to the title company two days before closing, now TRID requires that amount to be delivered three to seven days prior to closing; it puts the onus on the mortgage company to make sure that happens, Langevin explained. In response, the Guild team determined they would need to offer additional training programs for real estate agents to ensure they understood the change.

The learning department was simultaneously updating the company’s outdated learning management system with a more robust solution that could customize content for specific employees, allow managers to track their team’s progress, and integrate with Guild’s broader human resource management system. “Having an intuitive and flexible LMS was important for TRID because we were developing a lot of training paths for different employee groups,” said Dave Robertson, director of training. They ultimately chose Absorb LMS.

While implementing the new tool, Robertson’s team worked closely with subject matter experts to build TRID content, including webinars, train the trainer courses, lunch and learns and interactive online training modules. He was directly involved in designing nine online modules for the course, which offered most of the baseline information about TRID in fun, interactive ways using cartoons, videos, drag-and-drop exercises and quizzes. “We could have gone with a basic read-only format, but it would have been harder to retain,” he said. “So, we invested the extra time to make it more engaging.”

The SMEs occasionally pushed back on certain elements that didn’t accurately reflect the rule, but relied on Robertson to define the flow and learning environment. By the third module they had the design process down to a routine. “We began to understand each other, which made things run more smoothly.”

#DontGetTrumpedByTRID

In February 2015, they began rolling out training in incremental stages. “TRID is so complex that we knew we needed to take a layered approach,” said Lisa Klika, senior vice president of compliance and quality assurance. They started with a big picture, 30-minute course introducing the new rule to the company via live webinars where participants could call in and ask questions.

Those events were recorded and offered through the company’s learning management system for anyone who missed them, said Carolyn Frank, vice president of HR. “Over time the training got more granular.”

Later courses were customized to specific roles and responsibilities, including loan officers, funders and underwriters. The learning team created a matrix of job roles and training topics that integrated into the LMS to ensure everyone was assigned the necessary courses, and that managers could track their progress and hold them accountable if they weren’t completed.

As courses rolled out, the operations, compliance and training team launched a TRID training communications campaign with hashtag themes, like #dontgettrumpedbyTRID, and email trivia contests that challenged employees to answer TRID questions based on recently completed training. Trivia challenges reinforced newly acquired knowledge and let the training team know if content wasn’t sticking, Langevin said. “Based on our response analysis we could see where we needed to make changes.”

The training team also kept employees constantly updated on what courses they needed to complete, how it would help them in their jobs, and details on their long-term training plan. “They always knew what was coming so there were no surprises,” Robertson said. It also set the tone that this was an important program, and that the company’s leaders were paying attention to their progress. “That message was very important to the success of the program.”

Along with teaching employees about TRID, the team taught sales reps to train customers and partners about the rule, and how it would impact their business relationships. This served a dual purpose, Klika said. “It ensured our sales people understood the rule enough to teach it, and it gave them an opportunity to get in front of our business partners to demonstrate their expertise in TRID. That earned us a lot of credibility.”

As the go-live date neared, the learning team targeted leaders in each operation center with a final test: complete three mock loans using the updated processing system without making any mistakes. Once they passed the test, they became the resident experts, holding their teams accountable to complete the same challenge, Langevin said. “It was one last opportunity for everyone to practice for TRID in a safe environment, which gave them a sense of confidence that they were ready.”

Better than the Competition

Based on initial results, they were right. “By the time October 3 rolled around, our people were proficient in TRID,” Blocker said. “The training program saved us from making critical errors and enabled us to bridge the gap from the old way of doing things to the new.”

By December 2015, the company had delivered 6,400 hours of TRID training, and every employee had taken part in at least one course. The content is offered to new employees and to anyone who wants a refresher course through the LMS.

Klika said the first months were hard, but by December employees were closing loans on time, with fewer errors, changes and delays than many of their peers.

Guild became known throughout the banking industry as a company ready for this disruption. “We have received feedback from a number of industry partners that we ‘get TRID’ better than any other company, and that our sales force is very prepared,” said Blocker.

The company also has experienced rapid growth since TRID, adding roughly 700 new employees in 12 months. “It is another indication of our success,” Klika said.

Learning TRID and developing training to prepare the company was a long and grueling process, but it was worth it in the end, Frank said, because it set-up Guild and its employees, for success. “They felt empowered by this training, and they saw that we were investing in their future.”

Sarah Fister Gale is a writer based in Chicago. Comment below, or email editor@CLOmedia.com.

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