It's apparent that you’ll need clear processes and guidelines in place for your workforce to maintain high levels of service while working within strict tolerances that could result in game-changing fines for your business.

The primary issue is not only delivering the closing documents to the consumer three days ahead of closing (consummation), but now, with the delivery deadlines and tolerance requirements, the lender is on the hook to ensure even greater accuracy of the GFE/TIL at time of application.  

The stakes are raised even higher because these penalties are assessed per day rather than per infraction, and the violation doesn’t need to be “knowing” or “reckless” in order to merit a penalty.

We rounded out section 16 of the TILA-RESPA Integrated disclosure rule regarding implementation by discussing the training component your organization will face. In the summary published by the CFPB, I think it’s one of the shortest sections – but we as an industry know better than to just think about it as two sentences.  

How much of the TILA-RESPA rule implementation have you discussed and planned for in your organization?