Well, the dreaded “October 3” date has passed and we are all still here, our doors are open, and members are conducting business as usual as if nothing momentous such as, oh I don’t know, maybe a major shake-up in mortgage origination happened. Whew!

So, do you think it was mere coincidence that the CFPB changed the implementation date to the spookiest month on the calendar? Do you think they understand the double, double toil and trouble everyone has been through the last few weeks and months? It was enough to bring bats to the belfry and have us all seeing black cats crossing our paths!

Now that the date has passed and we are in the trenches of seeing how all this works out, what should we do next? We’ve spent a LOT of time preparing, but what should we be thinking about as the dust settles on this most recent Halloween Trick?

First, pat yourself on the back. It’s been a long road, but you’ve done all you could to get your credit union ready for this. Then, step back and start looking at your processes and procedures. It’s very easy to provide training about how a process SHOULD work, but often we find things don’t work exactly as we intended. So, review procedures and see if they need to be tweaked.

And, what about that training? Have you found there were things you didn’t consider when everyone was trained? Should you provide a “post-mortem” wrap-up of new discoveries or adjustments that need to be made? Would regular meetings be helpful for a while, just to talk about how everything is working?

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