Don't expect CFPB to cut you any slack on new mortgage disclosure rules

The new Consumer Financial Protection Bureau mortgage disclosure rule takes effect in less than seven months. While that sounds like a long way off, experts say that the disclosures involve so many parts of the origination process it will takes months to plan and put in place a new system and months more to test it. And, having provided a long ramp-up period, the CFPB is unlikely to allow any grace period beyond the August 1, 2015, deadline. The new disclosure requirements will entail far more than learning what to put in which box. You'll need to revisit your application process to be sure you don't trip disclosure triggers unexpectedly or miss cues that make the communiques unnecessary. You'll need to standardize fee names so that everything appears where, and how, it must. You'll need to establish ways to keep an eye on fee changes between application and closing so that a borrower's decisions don't leave you holding the bag for compliance failures. And you'll need to train staff so they know which forms to issue and when. Learn all about the Loan Estimate and Closing Disclosure forms and the rules around them in IMF's Guide to the CFPB's Mortgage Disclosure Requirements. The report covers such topics as timing of disclosures, recordkeeping, liability and redisclosures. It also includes a lender perspective section that spotlights important points in the rules that could require major changes in your processes and provides valuable implementation tips.     Contents include: Disclosure Requirements Definition of a Loan Application Limitation on Fees and Verification Permissible Changes Between Disclosures Exceptions to Permitted Changes Recordkeeping Requirements Liability Under Disclosure Laws Electronic Disclosure Requirements Loan Estimate Itemized Disclosure of Individual Charges Disclosure of Broker Compensation Servicing Disclosure Re-Disclosure Closing Disclosure Escrows Permitted Changes After Closing Lender Perspective Early Planning Tips Intent to Proceed Locking the Interest Rate After Disclosure Timing and Accuracy on Closing Disclosure Tolerances as a 'Moving Target' Liability After Foreclosure Errors Discovered After Closing Use this handy guide to map out the steps you need to take to prepare for the new mortgage disclosure requirements.

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