by: Henry Meier
Don’t be fooled by the fact that it’s a beautiful morning here in Albany New York and Memorial Day is right around the Corner. These are actually compliance omens. It means that time is running out for your credit union to take a serious look at how it plans to comply with the new integrated disclosure requirements that kick in for mortgage applications received on or after August 1. You will be providing a loan Estimate and a Closing Document to your members.
My concern is that, whereas the industry spent months fretting over the QM rules, the sense I get is that the integrated disclosure rules haven’t generated the same angst. To the extent this is because you have used the last year to get ready I apologize and you can go on with your day. To the extent that there are some of you who think this rule is something that your vendor will take care of grab a second cup of coffee-this is admittedly dry reading in the morning-and ask yourself these basic operational questions. The new mortgage disclosures involve operational considerations that will impact your credit union’s bottom line.
Are you ready to make sure that your anxious homebuyers receive their Closing Disclosures at least three days before the loan is consummated?
This is probably the change with which you are most familiar. The days of a member getting the HUD1 at closing are over. With very narrow exceptions a Closing Disclosure must be received at least three business days before consummation. (A business day for purposes of the closing Disclosure requirement is all calendar days except Sundays and legal holidays)continue reading »