Shifting gears on TILA-RESPA
Our weekly summary
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TILA-RESPA Implementation. How much of this have you discussed and planned in your organization? This week we will continue to discuss the implementation portion of the TILA-RESPA rule, so let’s quickly recap what we talked about last week.
We dove a bit deeper into the tolerances of the loan estimate, primarily around the circumstances where charges on the Loan Estimate form can change without any violations to the “tolerance” thresholds. In this portion of the rule, the CFPB clearly spells out in what instances creditors are permitted to charge more than disclosed on the Loan Estimate, charges that may change without regard to a tolerance limitation, and charges that are subject to a 10% cumulative tolerance.
Also discussed was the ability for consumers to shop for settlement services. We asked some questions to get your opinion on this, and if you’ve already embraced this change with consumers. As a reminder, identification of at least one available settlement provider for each service, and stating that the consumer may choose a different provider of that particular service are the two main points of that portion of the rule.
And of course, we started discussing the portion of the rule regarding implementation, which leads us back to the posts for the next two weeks. We’ll be starting a new post schedule this week. Going forward, we’ll be publishing posts on this blog every Monday, Wednesday and Friday, with Monday posts still summarizing each week. We’ll be discussing some heavy topics as we tread through the implementation portion of the rule, and we hope it’s both eye-opening and helpful to you and your organization.
For more information about the impacts of TILA-RESPA on your business, and how technology solutions can help you overcome them, visit www.TILAPRESPA.com to view a growing knowledge base of information and forums where you can ask questions.
All information and views expressed or implied are provided without warranty and are only the opinion of Pavaso, Inc. Each participant should seek legal representation for legal interpretation of the ruling and the CFPB directly for final instruction and interpretation. The final rule can be found here.