With just four months until the Aug. 1 implementation deadline, it's no surprise that CFPB's 1,900-page TILA-RESPA integrated mortgage disclosure rule is one of the NCUA's supervisory priorities for 2015. This complex rule combines several existing disclosures into two documents – the Loan Estimate and the Closing Disclosure. Combine recent TILA-RESPA amendments on rate locks, new construction loans and placement of the NMLSR ID – all having the same compliance deadline – and it's no wonder credit unions are scrambling to cover their bases.
Credit unions should have a plan of action for ensuring timely and accurate compliance. A good starting point is assignment of a project manager or implementation team to create/ track a compliance plan that includes an implementation map, stages of integration and a timeline.
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Some other key steps to consider include:
Amend policies and procedures
TILA-RESPA will require changes to current lending policies/procedures and can be addressed now. Staff will need to be trained on the new requirements.
Determine the products, departments and staff that will be affected by the rule
Origination, processing, closing and post-closing departments are the most likely to be broadly impacted.
Isolate the internal changes necessary for compliance
These might include business-process, operational and technology changes. Fully understanding required changes may involve a review of existing processes and the hardware/software your credit union or business partners use.
Identify impacts on third parties, and address accordingly
Software, forms providers and other vendors may offer compliance solutions to assist with necessary changes.
Ascertain training needs
Loan officers, processors, and closing and compliance staff, among others, will likely need training on the rule and the changes made to the credit union's policies and procedures.
TILA-RESPA is a time-sensitive but highly technical regulation. While it is pertinent to work towards timely compliance, NCUA recently has afforded some comfort. In response to NAFCU's request, NCUA Chairman Matz responded that NCUA will consider good faith efforts by credit unions to comply with the CFPB's TILA/RESPA integrated mortgage disclosure rule.
Jiji Bahhur is director of regulatory compliance for NAFCU. She can be reached at 703-842-2202 or [email protected].
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