Advancing to the end of the mortgage process and beyond closing, both the Loan Estimate and Closing Disclosure must be compliant (and defensible) to the end investor. Given the ambiguities within so many of the rules applicable to both forms, it is important to have a way to defend the programming logic used to define the output.
Industry talk quickly spread after a speech on Wednesday by Steven Antonakes, deputy director of the Consumer Financial Protection Bureau, where he seemed to suggest that the CFPB might delay the Integrated Disclosure deadline. The CFPB is putting an end to the rumors.
If you’re one of the lenders who hasn’t converted over to a digital closing platform yet, chances are you’re going to be a little lost (and even further behind) when that next phase of development kicks off about two months from now.
"Obviously there is a lot of fear, uncertainty and doubt in the industry with the TILA-RESPA ruling beginning to dominate conversations, and there is no doubt Aug. 1, 2015 is going to happen," McElroy said.
I think a number of companies do recognize the importance of these changes, but this is much more than just a change in a disclosure — the CFPB is using these disclosures as a vehicle for broader changes in the industry.
Almost like the terror of waking up that one morning in grade school thinking “Oh man, that science fair project is due today!” But don’t get that migraine just yet, you’ve got the next four weeks to hash this out.
At one year until the go-live date for the Integrated Disclosure Rule, if you haven’t started having meetings to discuss your organization’s approach to incorporating reforms, depending on its size, you could already be behind schedule.
With the recent turnover in leadership at the Federal Housing Finance Agency, we may be standing at the precipice of great change in the government’s role in supporting the mortgage market through Fannie Mae and Freddie Mac.