Market Share Report – January 2015

Decisions . . . Decisions . . . Decisions . . .

The August 1, 2015 implementation date for the new loan and closing disclosures will be here before we know it. Prior to that time, lenders will need to be making a number of process related decisions. Each decision is sure?to have an effect on the ability of lenders to be compliant with the new regulations. Of equal importance, each?decision will also be judged by the marketplace in the context of how reliable the lender is at meeting time?frames and how easy they are to work with.

Two critical decision areas are:

1. Is the lender going to prepare and deliver the closing disclosure (f/k/a HUD?1) to the borrower or is the?lender going to delegate that responsibility to the settlement agent? Or will the lender choose some?combination of both?
2. Is the lender going to confirm receipt of the closing disclosure by the borrower three days prior to?closing or is the lender going to mail the closing disclosure seven days prior to closing. If the lender?chooses to mail the disclosure, receipt of it by the borrower is presumed. Clearly less regulatory risk and?record keeping, but possibly more process issues surrounding working that far ahead.

Wells Fargo and Bank of America announced that they will prepare and deliver the closing disclosure in order to?minimize the regulatory risk. As both of those institutions have run afoul of the CFPB in recent times, minimizing?the regulatory risk is probably very important to them.

John Bethell Title will be prepared to close transactions under all the above scenarios. As your decision making?evolves, we are available to consult with you about the best way to integrate our respective responsibilities in?the most cost effective and compliant manner. Don?t hesitate to let us know how we can help.

We?re pleased to announce that Liz Bunton has been promoted to manager of our closing department. Liz joined?us three and half years ago as a transaction coordinator. She is well respected and liked by her teammates and?our clients. Liz will lead, manage, and be accountable for all aspects of our Anxiety Free Closing process and for?delivering upon our promise to provide an outstanding closing experience to our clients every day.

~John