Top 5 Things To Do With The Extra 63 Days

CFPB has moved the effective date again.

Dear Member,

Whew! What a week! By now you should all know that the CFPB has moved the effective date of the new TRID rules to October 1, 2015. Oops. Sorry. Just heard that they changed it again to October 3, 2015!

Here at The Fund we are busily re-scheduling the DoubleTime upgrade and the training webinars for the Closing Disclosure and DoubleTime. We are also updating the Readiness page to reflect the new date. So that you don't feel left out of all of the hustle and bustle resulting from last week's announcement, here are a few things for YOU to do with the extra 63 days that you now have before the rules kick into action.

1. Register with Closing Insight at www.closinginsight.com. This is the information platform that most of the large lenders will require that you use to send and receive loan information for a transaction. There is no reason to put off registration. I did a sample registration the other day and it was very user friendly. Only a few places where you hesitated about what to put. If you have questions, contact me or Leslie Anderson at landerson@thefund.com.

2. Collect information for your Contacts Module in DoubleTime (or the comparable section of your closing software) required for the new Closing Disclosure form. For example, you will need license numbers, emails and phone numbers for both sales agents AND brokers. Do this now as you are handling closings so there will be one less thing for you to deal with after October 3, 2015.

3. Talk to your lenders. We know how Bank of America, Wells Fargo, Chase and other large lenders are handling preparation and delivery of the Closing Disclosure. But if you regularly deal with small to mid-range lenders, you need to open a dialogue with them and ask them what their anticipated process is going to be and what they will expect from you.

4. Register for a Closing Disclosure Webinar and learn about the new form. Even if you have already done this – do it again! It does not hurt at all to hear it all a second time! Take advantage of our CFPB Hotline email and send your questions to us: cfpbfaq@thefund.com.

5. Make sure you and your staff are clear on your standard charges for a residential closing so that you are providing accurate information to the lenders.

Extra credit:

6. Reach out to the real estate agents that regularly refer business to you and start a dialogue with them about how the new rules will affect some of the contract terms they negotiate with buyers and sellers. For example, 30 day closings are probably not realistic. Clarity on the financing contingency provision is very important. Discuss how any change to the Closing Disclosure after it has been delivered to the borrower will get more scrutiny by the lender after October 3 so the real estate agent needs to really be on top of whether any changes are needed.

I hope you have found this information to be helpful. As always, thank you for your support of The Fund.

Best Regards,

Melissa Jay Murphy
Senior Vice President and
General Counsel