Today, the lending industry is abuzz with all the preparations necessary to implement Integrated Disclosures under RESPA/TILA this coming August. As well we should be, after all this is only going to change the way we’ve done business for the last 30 years. That’s right, we are bidding farewell the old ways of providing a Good Faith Estimate (GFE) and an initial Truth-in-Lending (TIL) as part of the application/initial disclosure process. So long are the days of closing out transactions with a Final TIL and the HUD-1 Settlement Statement. Soon we’ll be moving to the new Loan Estimate and Closing Disclosure, both hitting the scene on Aug. 1, 2015. And while there is much to discuss on the new Integrated Disclosure rules, that’s not what we’re discussing today. Instead, in the words of the late Paul Harvey, we are going to explore … the rest of the story. What do I mean? Think about every single time or place your organization references one of the following in some written format:
►GFE
►RESPA
►TILA
►HUD-1
►Settlement Statement
►Closing Statement
►Initial Disclosures
►Or some variation of these terms
What sort of documents might be impacted? That’s an excellent question. Since my team is responsible for the authorship and maintenance of about 40 compliance policy manuals (www.AllRegs.com) in the mortgage lending space it is a question we’ve been asking early, and often, to ensure we’re accurately addressing the needs of our clients and business partners. For all of us out there working hard to remain ahead of the curve and compliant, there’s more to do.
For example, we have identified that of our roughly 40 documents, nearly half reference the traditional RESPA/TILA requirements I mentioned above. Think about that. Fifty percent of our material requires a touch in order to adjust for Integrated Disclosures.
What does that mean to you? Well, I’m not sure, but I’m certain it means something.
For example, what about your training materials? Any references there? Job aids? Do they reference any of the terms listed above? What about your form letters, or system guidance?
What about marketing materials or borrower education content?
The point I’m trying to make is there is more to the process than just taming the RESPA/TILA beast (ROAR)—which is a significant endeavor. It’s about understanding and responding to the MANY rolling impacts these regulatory changes present to us all. Set aside some time to review your document libraries and find the language, references, and links that might be affected. An ounce of prevention is worth a pound of cure—especially when prescribed by an auditor.
Good luck and stay compliant.
Joy K. Gilpin is professional services manager with AllRegs. She may be reached by phone at (800) 848-4904.
This article originally appeared in the February 2015 print edition of National Mortgage Professional Magazine.
