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CFPB RESPA/TILA Rule Reference: 16.0-16.1, page 86, CFPB Detailed summary of the rule
Here we are in mid-summer 2014. The “Final” Integrated Disclosure Rule has been published for almost nine months, and we’ve all attended at least a couple of webinars and conferences to learn about what it might mean for our individual firms.
As we rapidly approach the start of the 1-year countdown to TILA-RESPA go-live, though, it’s time that we transition from our theories and tire-kicking into planning mode. How are we going to tackle this thing in the real world?
If they haven’t already, now is the time for leadership at each lending organization to start soliciting advice from counsel and/or the compliance officer in order to set overall program direction and to weigh-in on project budgets. And the compliance team needs to be engaging operations and technology departments now to develop those budget proposals. Depending on the depth and breadth of the organization, planning your implementation approach in the new year may well prove to be too late.
As we’ve mentioned on Closing Call before, the implementation date for the Integrated Disclosure Rule is August 1, 2015, and there is no stagger in the schedule. To be clear, all mortgage applications prior to 8/1/2015 will use today’s document set (GFE, initial TIL, HUD-1, etc.), and applications on and after 8/1 will leverage the new Loan Estimate and, ultimately, the Closing Disclosure Form. If for no other reason than the fact that roll-out will need to happen literally overnight, all lenders should have a clear and thorough implementation plan sooner rather than later.
The first step in maintaining a leading-class compliance program will be to conduct an analysis of all impacted roles and processes and to generate a gap report. It’s likely that, at least, your origination, processing, closing, and post-closing staff and processes will be impacted, and it’s likely to be the prime time to modernize some of your technology solutions.
The good news is that many of the technology service providers in the industry are looking first at retrofitting existing systems through upgrades. Shop smartly. Look for providers who can leverage what you already have and focus on enhancing it for today’s business world.
As we often do with large roll-outs, you should consider engaging outside consulting. Look for advisors who can provide services around legal compliance, policy analysis, process/controls reform, training, change management, and technology enablement. Of these, it’s the latter — technology enablement — which will have the greatest variable influence over the final project budget. Check back tomorrow for a deeper dive into this topic.
At Pavaso, we’re developing a turn-key implementation program where we take everything mentioned here into consideration for you. For implementation areas we wouldn’t necessarily cover in-house, legal analysis for example, we’re partnering with some of the top names in consulting to deliver those component pieces of one overarching Pavaso program. Our implementation approach is a reflection of our flagship product, Digital Close, in that it starts with an understanding that the complexity of this industry means that the best solution will only be developed by several different experienced entities acting in close cooperation.
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.