Even though the mortgage industry is moving toward the goal of removing paper from the mortgage process, closing a loan still comes down to executing a collection of documents. Whether these docs remain in digital form or are printed on paper, these documents and the data that populates these documents determines the difference between a quality, profitable loan and a costly problem for the lender.
How can you find the diamond in the rough in the world of mortgage document compliance?
What can lenders expect from Washington in 2017?
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.
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.
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.
Recently, we provided a comment letter for the CFPB. We covered a great deal of ground in our letter and could only give you the briefest of overviews in our post. After it was published, the post got a lot of attention and we were asked for more specifics about our comments.
Congratulations! You’ve survived TRID. You’ve adjusted to the Qualified Mortgage standards. All of your loan officers have been licensed in compliance with the NMLS standard.
As the Consumer Financial Protection Bureau (CFPB) works to refine the rules it has established for our industry, we are called upon to provide comments to help the Bureau work through that process, and having lived through the earlier iterations of the CFPB’s rules, it is in our best interest to do so.
