02.09.17

Should Non-Purchasing Entities Sign the Closing Disclosure?

Per its normal procedures, the Consumer Financial Protection Bureau (“CFPB”) requested comments on its proposed amendments to Regulation Z, commonly referred to as the “TRID Amendments.” In response, we provided a comment letter regarding these amendments, not only since they will impact our clients and ourselves once implemented, but also to share our expertise – cultivated through 25 years of providing vendor services – with the CFPB.

 

After posting a blog about our comments, we’ve received requests for more specifics as to their content. To oblige these requests, we are posting excerpts from our letter.

 

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02.07.17

TILA-RESPA Integrated Disclosure Amendments and Disclosing Revised Amounts

Per its normal procedures, the Consumer Financial Protection Bureau (“CFPB”) requested comments on its proposed amendments to Regulation Z, commonly referred to as the “TRID Amendments.” In response, we provided a comment letter regarding these amendments, not only since they will impact our clients and ourselves once implemented, but also to share our expertise – cultivated through 25 years of providing vendor services – with the CFPB.

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01.10.17

The Countdown to UCD is On

One of the most significant data changes coming in 2017 will be the delivery of the Uniform Closing Dataset (UCD) to Fannie Mae and Freddie Mac, which becomes mandatory on September 25, 2017. The UCD is a component of the GSEs’ Uniform Mortgage Data Program® (UMDP®) which defines data initiatives for loan closing, collateral, appraisal and loan delivery, in order to enhance data quality and standardization for the industry. UCD defines common industry data around the Consumer Financial Protection Bureau’s (CFPB) integrated disclosure laws; lenders will now be able to transmit the CFPB Closing Disclosure documents and data electronically. This way, regulators and the GSEs see “what the borrower sees.” The files also create an accurate loan file that is consistent for all lenders who sell loans to the GSEs.

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10.11.16

TRID 2.0 – Clearing the Clouds of Uncertainty

After nearly nine months of watching lenders struggle to fully implement the TILA-RESPA Integrated Disclosures (TRID) regulations that went live in late 2015, the Consumer Financial Protection Bureau (CFPB) released a series of proposed amendments. While there are no large individual changes, depending on a business’s practices, there are several small tweaks that could greatly impact the lender’s processes and procedures.

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06.21.16

They’re Baaaaack: CFPB to Reopen TRID Rulemaking

For much of the past 18 months, the mortgage industry has been solely focused on one thing—TRID. And although the TRID deadline has come and passed, the industry is not quite finished with the recent guidance. Just when you thought it was safe to get back in the water, the CFPB has reopened its TRID rulemaking.

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