CFPB RESPA/TILA Rule Reference: 16.3, page 87, CFPB Detailed summary of the rule
This week, as we start the one-year countdown to the August 1, 2015 Integrated Disclosure Rule go-live, we’re kicking-off a dialogue about how to start getting ready. On Wednesday we talked about assessing your technology now while you still have time to research different options, since the costs of upgrades or new systems can significantly impact the entire project budget and effort. But in order to generate an altogether solid implementation plan, you’ll need to take a look at all of your third-party service providers.
Real estate is a complex industry with many business partners touching even a single transaction; a clear understanding of the relationships between your businesses is crucial for successfully mitigating risk and protecting revenue for all involved.
A leading class implementation plan will involve mapping out all workflows impacted by TILA-RESPA including those pieces taking place in correspondent locations, with secondary market partners, technology vendors, and in title and settlement companies.
You need to know what each vendor does for your organization, specifically, and exactly what it takes to get that job done. An underestimated level-of-effort from a service provider is the greatest likely candidate for throwing your project plan off track, and this is the reason you should be having these conversations today with your partners.
As a sidebar: also be aware that, depending of the type of service provided, these vendors may receive more and more change requests as the go-live date gets closer, and they may not be able to cope. Remember this ruling affects many different layers and aspects of the mortgage industry; waiting too long to engage the right people for your organization could be a catastrophic misstep and leave you with only sub-optimal choices.
The takeaway from today’s post is know your business and use that knowledge to develop a thorough and strategic roll-out plan. At one year until the go-live date for the Integrated Disclosure Rule, if you haven’t started having meetings to discuss your organization’s approach to incorporating reforms, depending on its size, you could already be behind schedule.
And if you haven’t heard any water cooler chatter about your company’s plan for addressing the Integrated Disclosure Rule, I challenge you to send three emails today to ask leadership and/or colleagues: When are we going to develop our TILA-RESPA implementation approach?
Within the next week we’ll be posting some helpful information to the TILA-RESPA Knowledge Center regarding implementation. Be sure to register for your free account there so you can check it out.
All information and views expressed or implied are provided without warranty and are only the opinion of Pavaso, Inc. Each participant should seek legal representation for legal interpretation of the ruling and the CFPB directly for final instruction and interpretation. The final rule can be found here.
