As we first pointed out two weeks ago regarding the implementation section of the TILA-RESPA Integrated Disclosure Rule, weeks 50-44 are the initial portion of the Lender Implementation Timeline – the portion where you should be conducting project research and budget approval for TILA-RESPA compliance.
To keep it handy, we’ve included the Lender Implementation Timeline graphic for a quick refresher (we also have a print-ready version in the TILA-RESPA Knowledge Center here). Why are we digging up this timeline again? Next week is Week 50 of the countdown to August 1, 2015.
So, are you ready to get started on Monday?
I can already feel some of the shock through the data pipelines of the net already. Almost like the terror of waking up that one morning in grade school thinking “Oh man, that science fair project is due today!” But don’t get that migraine just yet, you’ve got the next four weeks to hash this out. And while you move that ball down the court, here’s 5 helpful things to consider:
1. Get a matrix going of the vendors your business depends on. You’ll need to go down the list and reach out to every one of them in order to understand what they’ll be doing to help you be compliant.
2. Understand how the people in your organization will be affected. Note who they are, what they’ll need to learn and comprehend to be compliant, where they are geographically located, and if current training solutions suffice in getting them up to speed.
3. Look at your current business processes. Take a good look at what you do today. What must you change to conform to the new rule? Are there any opportunities to get more efficient since you’re investing in such a big change?
4. Identify the pitfalls that your current technology doesn’t handle. While you’ll do this in greater detail during weeks 42-28, it will help you gain a rough cost as you look at technology solutions that can provide real-time collaboration and sharing between you, your business partners, and the consumer.
5. Be brutally honest with yourself. If you don’t have a particular skill in-house needed to plan or execute any portion of the plan, hire for it, or find it with a trusted vendor that can knock it out of the park. With anything from project-planning to solution/vendor comparison and selection, don’t let the weakest link go unattended.
At first glance of the ruling, I can see how one would potentially think that all of this mess will just be a form change. But as we’ve pointed out in this blog, there’s much more than meets the eye. We’re talking business process revisions, and in many cases, complete overhauls of some processes. We’re talking getting your people up to speed, and even branching that out to your extended people like business partners and vendors to make sure they’re on the same page with you. And most importantly, implementing technology that will transform your closings.
What isn’t being discussed to great length during this entire CFPB initiative is that the consumer is going to have a much higher set of expectations. And like other industries have recently seen, a digital transformation of the way they do business simply can’t be ignored anymore.
For a variety of information on solutions to TILA-RESPA, visit the TILA-RESPA Knowledge Center where you can register for a free account to browse a knowledge base of articles and documents, or join conversations in the forums.
All information and views expressed or implied are provided without warranty and are only the opinion of Pavaso, Inc. Each participant should seek legal representation for legal interpretation of the ruling and the CFPB directly for final instruction and interpretation. The final rule can be found here.
