4 things to ponder on Monday AM
by. Henry Meier
If you are like me, you haven’t been paying much attention to the news over the past few days, so here are 4 things to ponder as you begin your credit union work week.
- The CFPB recently issued a guide instructing lenders how to comply with the combined TILA-RESPA integrated disclosures that take effect August, 2015. The CFPB does a phenomenal job with these guides in which it cuts through the more technical aspects of its regulations and provides lenders with practical tips on complying with some of its lending regulations. I know some of you have understandably taken a break from obsessing about mortgages now that you have gotten your qualified mortgages policies and procedures up and running (you have, right?) but you should remember that the CFPB’s regulation introducing brand new lending application and closing disclosures will have a huge operational impact on those of you who provide mortgages. For example, closing disclosures will generally have to be provided three business days before closing. To me this remains one of the most foolish requirements promulgated by the CFPB, but I hope I am wrong with this prediction. On the bright side I have always been disgusted by the needlessly complicated disclosure process we use when buying and selling houses and in my opinion these new integrated disclosures can’t be any worse that the current disclosures provided to home buyers. Bottom line, take a look at the manual. It is not too early to see how you are going to comply with these new requirements.
