140 days and counting until the Consumer Financial Protection Bureau's (CFPB) TILA/RESPA Integrated Mortgage Disclosure (TRID) rule goes into effect. If you haven't paid much attention, now is the time to start.

Just this week, more lenders confirmed they will take control of delivering the Closing Disclosure to customers, and use technology tools that mean many will no longer accept fax or email.

We're not just talking about a change in forms. This is a change in business process, a change in customer communications, and ultimately a change to protect consumers when they shop for a mortgage loan and close a residential real estate transaction.

Stewart continues to lead in being "CFPB-ready," and we want to know what lenders are doing. From the large, national lenders to your local banks and credit unions, are they prepared for August 1?

Thus, our Lender Outreach Program Survey begins this week. Working together, Direct Operations and Stewart Lender Services will ask lenders for their strategy and plans for implementing the new disclosures. We would like to collect information from as many lenders as possible. An executive summary and white paper will be provided to you and to responding lenders, providing insight on lenders' direction, and how they will connect and communicate with settlement and closing agencies.
Some of What We Will Ask Lenders

  • Where are you in the planning stages?
  • Do you anticipate being compliant by August 1? If not, are you engaging other providers to assist you with implementing the changes?
  • Will you produce the final Closing Disclosure, or are you asking settlement agents to produce?
  • How will you collaborate with settlement agents to complete the Closing Disclosure?
  • Are you planning to use technology to collect and collaborate on fees for the purpose of producing the Loan Estimate and/or Closing Disclosure?  If so, which technology?
  • Do you expect integrated systems? If so, which loan origination systems will you expect settlement agents to integrate with?
  • How will the work flow?
  • How do you expect to deliver the Closing Disclosure to the consumer? (email, online portal, postal mail?)
  • How will you track and retain evidence of fee changes on the Closing Disclosure for compliance?
  • How will the process differ between purchase and refinance?

Survey Details

  • Launched Monday, March 16 to Direct Operations lenders in the vetting/due diligence database, plus Stewart Lender Services lender customers
  • Administering internally through our third-party survey tool, Zarca
  • Responses, follow-ups and analysis all tracked and compiled within Zarca
  • Initial results will be compiled in early April for the Executive Summary, white paper for the industry and lenders who responded
  • Offices can utilize the white paper to follow up with local lender customers

Leading this collaborative effort are Alan Frelix and Scott Gillen with our Stewart Lender Services group, in conjunction with Michelle Esparza in Enterprise Sales, CFPB Program Manager Marvin Stone, Mick Goodenough in Direct Operations Sales and numerous others. We're keeping our Direct Operations CFPB Designated Speakers and Business Development Officers informed as well, so they are prepared in their local markets.

While this is just one part of the August 1 readiness, it's one of the most important parts. Lenders are ultimately accountable to regulators to be in compliance with the new rules, and to ensure their service providers are prepared and compliant. This is a huge opportunity to lead with our lender customers; refine how we do business, the products and services we provide; and increase the communication and collaboration throughout the real estate transaction process.

Should you have any questions, please speak with your manager or email cfpbtaskforce@stewart.com.

August 1, here we come!