October 3, 2015 is the new go-day for implementation of the real estate closing procedures required by the CFPB. The requirements and combined TILA-RESPA forms have caused a lot of worry and consternation in the real estate community, and several efforts have been made to delay implementation of the changes. The time for delays has passed now that the CFPB has settled on an October 3, 2015 implementation date. Therefore, now really is the time for real estate closers to take a good, hard look at their processes and make sure they are ready and able to facilitate real estate closings.
Here are five questions to ask yourself to determine your readiness for TILA-REPSA.
- What are the new disclosure forms and what makes them unique?
There are two new forms that must be used for all real estate closings come October 3, 2015. These are the Loan Estimate and Closing Disclosure forms. They combine the overlapping data requirements of four of the current TILA and RESPA forms into two less confusing documents. The forms are easier for consumers to understand by providing consistent language and greater transparency into closing costs. They also eliminate duplicate data entry, make it easier to find key data, and should save time during the actual closing.
- What impact will this have on my business?
In addition to replacing current forms with the new ones, the new requirements change the way data is shared, paperwork is submitted, and the timeframes during which data must be shared between lenders, closers, and consumers. Manual and PDF submission of forms will no longer be accepted, for example. By some perspectives, these requirements are more onerous than the current system, but they offer a chance to streamline closing procedures, add transparency to the closing process, and reduce data entry demands and the related risk of mistakes.
- Will I need to update my software?
Yes, the forms are completely new and not available in any current software programs. If you plan to continue using real estate closing software, you’ll need to purchase new software that is compliant with the changes, or ask your current provider if an update that includes the changes will be made available.
- How ready is my software vendor for the upcoming changes?
That depends. Some software vendors took a very proactive approach to the CFPB ruling when it first came out in 2011. They began developing new software that would be in compliance and ready to go in 2015. Others took a wait-and-see approach in the hopes that the ruling would be overturned or delayed. They are now scrambling to catch up and have new products in place to comply with the new requirements. There is a third group of software vendors who have chosen to do nothing. Ask your current software vendor what their plan is and what, if any, products they will have available to bring your firm into compliance with TRID.
- Do I have a training plan in place?
Training on the new software and use of the new forms will ease the transition and give you more confidence in your abilities to facilitate real estate closings. Ask your software vendor about training opportunities and what type of technical support they provide on the new software. Make sure everyone in the firm who works with real estate closings knows about the TRID changes and is trained on the new system. The penalties for non-compliance are severe.
Easysoft Is Ready For TILA-RESPA, Are You?
Easysoft was one of the few software vendors to take an aggressively proactive approach to the CFPB ruling. The result is our new software program, EasyCDF, which is fully compliant with TRID and all of the new CFPB real estate closing requirements. Compliance with the new TILA-RESPA forms really is as easy as filling in the blanks with Easysoft there to help you.
Contact Easysoft at 1-800-905-7638 to learn more about EasyCDF and how it can help your firm meet the challenges of TRID this October.