Compliance asInfrastructure, Not a Checklist
TRID timers that survive server restarts. QM/ATR 8-factor verification per 12 CFR § 1026.43(c). HMDA auto-population of 110+ LAR fields. 10 compliance MCP tools accessible to any connected AI agent.
Why Temporal for TRID?
Most LOS platforms enforce TRID with rule-based alerts — a flag that fires when a deadline is approaching. If the server restarts, or a deployment happens, or a worker process crashes, that alert may never fire.
Confer enforces TRID compliance using Temporal durable execution workflows. Temporal persists workflow state through server restarts, deployments, and failures. Each TRID timer is a workflow that cannot be lost — it resumes exactly where it left off, regardless of what happens at the infrastructure level.
TRID Timers Managed by Temporal
| Timer | Duration | Trigger | Standard |
|---|---|---|---|
| CD Waiting Period | 3 business days | CD sent to borrower | TRID § 1026.19(f)(1)(ii) |
| Intent to Proceed | 10 business days | LE delivered | TRID § 1026.19(e)(2)(i)(A) |
| LE Delivery | 3 business days | Application received | TRID § 1026.19(e)(1)(iii)(A) |
| Revised LE (COC) | Tolerance deadlines | Change of Circumstance | TRID § 1026.19(e)(4) |
When a timer expires, the workflow triggers the next pipeline action — clear-to-close confirmation, compliance alert, or regulatory flag — without human intervention.
7-Year Immutable Audit Trail
Every compliance decision — QM determination, TRID timer start/stop, tolerance check result, adverse action generation — is logged and retained for 7 years. Records are immutable and cannot be edited or deleted after creation.
Regulation Coverage
TRID
CriticalTemporal durable timers for Loan Estimate (3-BD), intent-to-proceed (10-BD), and Closing Disclosure (3-BD) windows. Survive server restarts.
QM / ATR
CriticalAll 8 ATR factors per 12 CFR § 1026.43(c). QM status (General, Small Creditor, Balloon). Safe Harbor vs. Rebuttable Presumption. HPML threshold check. Points-and-fees ≤ 3% validation.
HMDA
High110+ LAR fields auto-populated from loan data. FFIEC edit-check validation. Annual export generation.
RESPA
HighChange-of-circumstance validation and tolerance resets. Fee bucketing across zero-tolerance, 10% tolerance, and no-tolerance categories.
HOEPA
HighHigh-cost mortgage detection. Rate and fee trigger checks against applicable thresholds.
ECOA
HighAdverse action notice generation with deadline tracking. 30-day and 60-day deadline enforcement.
OFAC
ModerateOFAC screening integration endpoint for borrower name and entity checks.
Post-Close QC
ModerateAutomated quality control audit via MCP tool. Surfaces data integrity issues before investor delivery.
QM/ATR — All 8 Factors, 12 CFR § 1026.43(c)
Confer verifies every factor required for Ability-to-Repay compliance.
| Factor | Requirement | Status |
|---|---|---|
| 1 | Current or expected income / assets | Verified |
| 2 | Current employment status | Verified |
| 3 | Monthly mortgage payment for the covered transaction | Verified |
| 4 | Monthly payment on simultaneous loans | Verified |
| 5 | Monthly payment for mortgage-related obligations | Verified |
| 6 | Current debt obligations, alimony, child support | Verified |
| 7 | Monthly debt-to-income ratio (DTI) | Verified |
| 8 | Residual income or assets after loan closing | Verified |
10 Compliance MCP Tools
Every compliance function is exposed as an MCP tool — any connected LLM or AI agent can invoke compliance checks through the open protocol.
run_trid_checkrun_hoepa_qmrun_tolerance_checkvalidate_coccheck_ecoa_deadlinegenerate_adverse_actioncheck_document_expiryrun_pre_uw_auditrun_post_close_qccompliance_dashboardQuestions
How does Confer prevent TRID violations?
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Confer enforces TRID compliance at the infrastructure level using Temporal durable workflows — not reminder emails or rule-based alerts. The 3-business-day Loan Estimate delivery window, the 10-business-day intent-to-proceed window, and the 3-business-day Closing Disclosure waiting period each run inside a dedicated Temporal workflow that persists through server restarts, deployments, and failures. A TRID timer cannot be skipped, misconfigured, or lost in a crash.
What QM categories does Confer verify?
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Confer's QM/ATR engine determines QM status across General QM, Small Creditor QM, and Balloon QM categories. It classifies loans as Safe Harbor or Rebuttable Presumption based on rate spread, checks HPML (Higher-Priced Mortgage Loan) thresholds against APOR, and validates points-and-fees against the 3% CFPB limit. All 8 ATR factors per 12 CFR § 1026.43(c) are verified.
How does HMDA auto-population work?
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Confer auto-populates 110+ HMDA LAR (Loan Application Register) fields from loan data collected during origination. Edit-check validation runs against the FFIEC HMDA submission specification. HMDA data export is generated per reporting cycle, reducing the manual data-entry burden at year-end reporting.
What is a 'change of circumstance' and how does Confer handle it?
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A change of circumstance (COC) is an event that justifies re-issuing a Loan Estimate with revised fees outside RESPA tolerance limits. Confer's compliance engine validates COC events, resets applicable tolerances, and ensures the re-disclosure timeline is met. Tolerance checking runs automatically on fee changes to prevent RESPA violations.
What is the dual wire approval for amounts over $500K?
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For wire transfers exceeding $500,000, Confer requires dual approval before the wire can be released. This is an anti-fraud safeguard that prevents a single user from authorizing large disbursements. Both approvals are logged in the audit trail with timestamps, approver identities, and wire details.
See Compliance in Action
Watch the TRID timer workflow, walk through the QM/ATR 8-factor check, and review the HMDA LAR auto-population with your compliance team.