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CFPB RESPA/TILA Rule Reference: 16.3, page 87, CFPB Detailed summary of the rule
Reviewing technology (systems and integrations), vendor practices and contracts, and internal and external workflows will arm you with the information you’ll need to develop a well-crafted implementation plan. Using the plan, your vendors and technologists can make updates and upgrades to the system, and legal can be hard at work updating policies and reviewing controls. But from an operations perspective, this will be your time to develop and begin to execute your training plan.
The specifics will vary by organization, but, in general, training will be necessary for your loan officers, processors, closing agents, notaries, compliance teams, and quality-control staff, at least. Your vendor management department may need to be brought into the loop as well. In the case of large national lenders, this effort could extend down to the personal banker level in bank branches—so we’re talking no small feat here.
It may also be necessary to monitor training efforts taking place within your vendors’ organizations, especially since there are circumstances under TILA-RESPA where the lender can be held responsible for vendor actions.
During the development of your implementation plan, you probably will have mapped out roles and processes as part of your policy and technology assessments. Use the roles identified during that process to determine who will need to undergo some training, and bear in mind that you may find that there are departments who are tangentially involved in the mortgage process who need to be involved.
After identifying all the particular roles, you will have decisions about the best way to deliver content, and this will depend, again, largely on the nature of your organization. Will your current training delivery infrastructure suffice for this roll-out? The number of people involved could drive the decision to develop some online training modules specifically for TILA-RESPA. And there will also be a decision about whether or not to outsource the training effort or bring in loan staff.
Decisions around training can sometimes be difficult because the advantages’ impacts on the bottom line aren’t always clear. There are many factors to consider but one is turnover. If your organization enjoys relatively solid retention, go ahead and invest in a quality program up front that leverages in-the-flesh trainers. If turnover is a challenge for your business, perhaps look into online models that will scale (and are repeatable) at a marginal cost.
As with the development of the implementation plan, it’s not too early to start working out some initial decisions around training. In particular, you’ll be served well if you can identify the affected roles as soon as feasible.
We've posted some helpful information to the TILA-RESPA Knowledge Center regarding implementation. Be sure to register for your free account there so you can check it out.
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.