TheMReport — News and strategies for the evolving mortgage marketplace.
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28 | Th e M Rep o RT Feature specialized valuation, title and compliance solutions from Accurate Group deliver. Maximize profits by mitigating losses on default and at-risk loans and REO sales – www.accurategroup.com 888-456-4383 Scan to learn more. 3MReport.indd complex process by which loans are evaluated and assigned risk from the rating agencies. However, within this process the consistent format for data and information has been the HUD-1. The "source of truth" document in the HUD-1 was used for fees and points testing, compliance testing, and data validation. Many of the due diligence processes, systems, and ratings assigned to loans today are designed around the HUD-1 format, data, and line number structures. Due diligence reviews, loan conduit structures, and other loan evaluation processes will need to be reenvisioned in light of the thousands of new documents that could replace the HUD-1. The Road Ahead: TRID's Potential Impact to the Mortgage Ecosystem T hroughout 40 years of mortgage origina- tions, lender's systems and processes have evolved, the GSEs have expanded, collapsed, and been reborn, and the secondary market was created and collapsed. Our technology has evolved from the typewriter to "green screens" to Windows to Web-based systems to SAAS models, but the one constant throughout the years has been the HUD-1. No one has ever said the HUD-1 format was ideal or perfect; in fact, it is far from it. But like it or not, it has been the one form and one source of con- sistent data upon which the entire mortgage market has been built. The HUD-1 sudden removal August 1 will undoubtedly have con- sequences and ramifications further reaching than we have contemplated in this article; we should all get prepared. This article aims to provide industry participants with information on recent developments. The content is intended for general information purposes only. It should not be relied upon or construed to be legal advice or legal opinion on any specific facts or circumstances and is subject to change. Extensive information about the upcoming changes can be found at www. consumerfinance.gov. CFPB ConFirms ThaT The augusT 1 TriD DeaDline is here To sTay I n late March, CFpB Deputy Director Steven Antonakes hinted in a speech at possibly extending the August 1 implementation deadline for new mortgage disclosure if vendors weren't ready. "To the extent there is new information or we're hearing directly from vendors that folks aren't going to be ready. . . we should continue to talk about that," Antonakes said. "I can't promise you [changes], but to the extent we will have a better understanding of the concerns, that is something we will consider." The CFpB recently introduced a new rule that allows consumers to post public detailed complaint narratives, something that has received industry criticism. While these comments threw the industry into frenzy, Sam Gilford, spokesman for the CFpB, was quick to clarify that the deadline will not be extended. "We have no plans to delay the deadline on the new mortgage disclosure forms. The industry should be prepared to begin using the new forms for loans with an initial application submitted on or after August 1," Gilford said. "The deputy director was pointing out that the Bureau is open to considering new information from stakeholders, not to delaying the deadline." Jason nadeau, is group president, Mortgage and Title Services, at Stewart. He is responsible for leading and developing comprehensive national mortgage services and title production. Additionally, Nadeau oversees Stewart Lender Services, the Company's national title production centers, and PropertyInfo Corporation, its real estate technology services company. scott Gillen, Scott Gillen is SVP, Strategic Initiatives for Stewart Lender Services. Gillen is re- sponsible for oversight of Stewart's product development and strategy related to product implementa- tion. Additionally, Gillen has direct management responsibilities over Stewart's Home Retention and Loss Mitigation initiatives. He oversees key client relationships as well as Stewart's GSE relationships. abe spohn is VP of Solutions Development at Stewart Lender Services. His focus centers around supporting the sales team, as well as operations, in the development of proposed solutions for clients. He works closely with the sales teams, operations, and IT to develop proposals and design solutions for the mortgage services division.