Implementation of the new TILA RESPA Integrated Disclosure has been pushed back to affect loan applications taken October 1, 2015 and thereafter. That’s good news because it will allow our industry more time to amend the rules affecting disclosure of title charges on the Closing Disclosure for the 21 states like Florida, where the buyer pays a flat simultaneous rate for a policy insuring his lender when the seller pays for the owners policy of title insurance insuring the new buyer. As it stands now, the Closing Disclosure form is really clear but what title companies are compelled to put in the boxes is really confusing. Another good news story is we can adjust to change when not in our busy season. So what’s the bad news? The bad news is delaying the three day wait period, so we now have more than two more months of getting loan figures and packages a couple hours ahead of closing (or at closing, or after the scheduled closing) and then scrambling to get it all done and give the clients the attention they need and deserve.
Posted in Phil's Corner.