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Posted by BobbiCT on 5/21/15 2:01pm
According to my title insurance company contacts, lenders can start using the NEW forms for loan applications taken AFTER August 1. Applications taken prior to 8/1 close with the "old" forms (GFE, TIL and HUD-1) and applications taken after 8/1 closed with the "new" forms (LE, TRID, CDs).
Means that for awhile lenders must use two different sets of criteria and software until loan applications in the pipeline before 8/1 are closed.
Also as of last Monday "new" software still being tested to see if it calculates and generates correct forms; no one trained to use it yet. CFPB hasn't agreed to a delay in implementation. No granting "waiver of fines and penalties" for any noncompliance or errors from August 1 to X month while "bugs" are being worked out. Some small lenders are going out of the residential loan business; cost of staff and attorneys to meet compliance, plus cost of software systems, too expensive for the profit margin - particularly with CFPB fines (unlimited amount, no cap - 8/1/2015 no longer under RESPA regulations, now all about the monetary fines).
Joke in my real estate world: August is a good month to be on vacation 
New terminology: CFPB has consumers going to a consummation. No longer using borrower or closing. |
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