Market Share Report – May 2015

June 22, 2015

Over the last few weeks I?ve talked with lenders about the August (Now! Woo Hoo!) October 1st Truth-in-Lending/RESPA disclosure changes. I?m happy that there seems to be a consistency in the conclusions?that are being made about the best way to comply with the new rules.

Every lender that I?ve talked with has decided that they will be the one delivering the Closing Disclosure?(CD) to the consumer. And all of them anticipate doing that with a confirmed receipt by the consumer as?opposed to mailing the disclosure seven days ahead of consummation (forever after herein referred to?as closing).

Lenders anticipate that the settlement agent will complete their portion of the CD and return to the?lender, so that it can be sent to the consumer. They also anticipate that any necessary amendments or?changes to the CD that happen in the disclosure period will be made by the settlement agent with the?Lender?s approval.

Many lenders are waiting for their software upgrade to be completed, tested and evaluated before?finalizing their process. Most anticipate this happening by the end of June.

Lenders will continue working from the purchase agreement closing date, but anticipate needing more?lead time to confirm a closing date. Seven to ten days is the time most often mentioned. And no lender?wants to issue a CD until the loan is clear to close.

No one has a good idea yet about how buyer mail-outs are going to work. An unanswered question is?whether the closing documents can be received prior to the end of the three day waiting period.

And finally everyone agrees that the required title insurance disclosure in the Loan Estimate is?confusing, convoluted and useless. Oh well. Maybe this can get straightened out in the extra sixty days?the CFPB gifted us.

Let me know if you?d like to talk about your specific situation.

~John