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Th e M Rep o RT | 17 2015 tila/respa update gathered during your own internal impact analysis. Develop and deliver hands-on training for applicable front–line operations and back-house operations staff to assist in understanding TILA- RESPA's impact on individual workflows. For example, the TRID regulation redefines what it means to take an applica- tion by eliminating a catch-all. There are now just six pieces of information that determine what is an application. Once a creditor has those six pieces of information, the application is considered "received." Once received, the timing requirements jump into play. So, lenders must review their current application processes and consider whether to "sequence" the gathering of these six items to ensure that it doesn't have an "application" before it intends to have an ap- plication. This is a crucial com- ponent to be addressed by any lender's workflow assessment. When developing a training plan, start with a broad-based regulatory overview of the new rule and its impact on current practices. You will likely need to provide your front–line opera- tions, back-house operations, cus- tomer support and sales groups, along with executive manage- ment and the Board of Directors, with a general understanding of the required documentation, process, and system changes triggered by the new rule. You may also consider providing additional guidance to help your institution address some of the new operational requirements. For the next phase of your training, focus on your own financial institution's products and features. Take a deep-dive review of the Loan Estimate and Closing Disclosure. Your objectives will be to give key members of your organiza- tion a detailed understanding of the required documents and compliant field data that drives the dynamic requirement for the regulation. Consider who needs to understand the forms and how to explain them. Make Your Changes Now and Relax Come August T he CFPB has been deeply engaged within industry discussions since the proposal was published and it is fair to expect that the Bureau will con- tinue to oversee how the industry measures up to TRID rule stan- dards and evaluate what changes, if any, may be needed in the future. The materials and guides that the CFPB has created are user-friendly, and it has provided a number of venues for discus- sions with vendors and creditors. How much your organization has taken advantage of the available resources will determine how prepared you feel for business to continue uninterrupted on and after August 1st. One thing is clear: given all of the time the CFPB has given the industry to prepare and all of the resources it has invested in education and discussions with impacted institu- tions, there will be little tolerance for non-compliance. There are no signs that exceptions will be made for originators who are not prepared. The good news is there is still time to act, there is just no time to delay. Be sure to address your questions now, understand the process implications now, and assess the readiness of your tech- nologies, so that you can keep the focus on your customers and grow your business safely and profitably. Kris stewart is the principal regulatory consultant and senior manager with Compliance Professional Services at Wolters Kluwer Financial Services. Jeanne ericKson is the senior and lead attorney for mortgage with Wolters Kluwer Financial Services. If You're Just Getting Started … If you're an institution that's just getting started in preparing for these massive changes, you are probably feeling overwhelmed. Don't worry, there are a lot of resources and part- ners available to help get you up to speed on the changes and steps you will need to take so you can continue to do business after the August 1, 2015 implementation date. The best place to start is with the source. The CFPB has an entire section of its website devoted to TILA-RESPA with helpful information to get you started. Most documents are in PDF format and feature user-friendly large text with key terms in bold type, or in MS Word format with searchable text using the "Find" function. Here is the main page: > Regula- tory Implementation > TILA-RES- PA (http://www.consumerfinance. gov/regulatory-implementation/ tila-respa/) On the main page, you will see numerous links to helpful informa- tion. Consider reviewing the links in the following order: Compliance Guide • A plain-language, user-friendly guide to the new rules. The FAQ format makes the content more accessible, especially for institutions that may have limited legal and compliance resources. • Read this document as an introduction and then read the Guide to Forms to broaden your understanding of terms and calculations. Guide to Forms • Provides detailed, illustrated in- structions on completing the Loan Estimate and Closing Disclosure. • Summary of TILA-RESPA Integration but much more de- tailed caption descriptions and calculation explanations than the Compliance Guide. • Great reference explaining the finer details of preparing the Loan Estimate and Closing Disclosure. Disclosure Timeline • Illustrates the process and timing of disclosures for a sample real estate purchase transaction. • Defines terms and sample scenarios with a sample events timeline. • Good desk reference, office/ group training and borrower education. Integrated Loan Disclosure Forms & Samples • Downloadable Loan Estimate and Closing Disclosure forms in both English & Spanish and samples for different loan types. The CFPB's published TILA-RESPA rule itself should serve as your primary source for information, but all of the resources mentioned above summarize the instructions for completing the Loan Estimate and Closing Disclosure. Here are some additional, important Regula- tion Z sections that you can review on the site: • The Preamble summarizes why the CFPB issued the rule, describes their legal authority, provides additional reasoning behind the rule, outlines re- sponses to comments, and of- fers an analysis of the benefits, costs, and impacts of the rule. • The Regulatory Text, which, when effective, will amend Regulation Z, can be found on page 1,365 in the main rule itself. • An Official Interpretation of the rules can be found on page 1,644 in the main rule.

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