CFPB TRID Amendments: what do they mean for the title and closing industry?

As many of you know, CFPB recently released amendments to its TRID rule.  While we would have preferred to see the CFPB address the owner’s title insurance calculations, not much changed from the proposal except the “optional” implementation date.

We think most title and closing software providers would agree that an “optional” implementation date is not helpful, in fact it only hurts us. One mandatory effective date, and no interim “effective date” would have been a much better option.  We need to be prepared to provide the changes to our customers once a lender starts requiring compliance with the amendments.  With an optional compliance date, various lenders can require settlement agents to provide updated documents, while other lenders, who wait to comply, will require the current documents.  Many software providers may have to scramble to provide a temporary solution for those lenders that decide to comply with the changes prior to October 1, 2018.  It will require a lot of work from settlement agents as well as software providers.

Whether or not October 1, 2018 date provides enough time to make the systems changes that are required for the new amendments is hard to say.  Right now, we are in the process of reviewing the final amendments, the impact of those changes on our products, and  a timeline required to make them to ensure our customers are compliant by the mandatory October 2018 date.

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