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CFPB RESPA/TILA Trigger Dates May Require “Plan B”

Last week I posted a document highlighting a sample loan process and the trigger dates associated with the file during processing. I asked for comments from the group as to how they planned to handle this quandary because getting these right is not an option; your company will have to be spot on!

I also reached out to several of you in operations as to how their companies are handling this new document and the trigger dates.

It seems that most companies are relying on the LOS coming up with something, and that may prove to be your Achilles heel!

So let’s fast forward to August 1, 2015. Your LOS has told you “don’t worry we’ve got this” and…..they don’t. What is Plan B?

I’ve attached an article which is a great read that illustrates this problem further. The big banks who count on their own software development departments profess that they will be ready. Everyone else may not, which will not only cause RESPA/TILA violations, but the likelihood of the investor not taking the loan.

It’s January, so there is no need to panic. However, it may be a great risk management play to have a Plan B, just in case your Plan A (your LOS) is not ready in time.

To Read the Article, CLICK HERE

Tammy Butler, Master CMB

Author Tammy Butler, Master CMB

More posts by Tammy Butler, Master CMB

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