January 10, 2014
With the first round of mortgage regulation becoming effective today, compliance solutions leader PolicyWorks is issuing a white paper to remind credit unions of the remaining mortgage compliance work they will need to address in 2014. Specifically, the paper’s authors address implementation of TILA-RESPA rules and testing of rules implemented in 2013.
TILA-RESPA rules consist of 1,888 pages, and credit unions must be in compliance by August 1, 2015.
“The final rule requires that credit unions use new disclosures, comply with the required timeline as to when forms are given to members and work within new limitations when changing a final deal from an original loan estimate,” writes PolicyWorks’ Jeff Andersen. “There is a great deal of work ahead in terms of readying policies, procedures and forms, as well as training staff to be sure they understand the new requirements.”
“If it sounds like a tall order, that’s because it will be for many credit unions that are engaged in the implementation and testing of several regulatory compliance projects.”
The authors also walk through best practices for testing of rules already implemented for mortgage-program compliance. These include:
Beginning as soon as possible vs. waiting for TILA-RESPA implementation to be complete.
Testing all procedures to cover the entire lending process – from underwriting to closing to debt collection.
Building up a sizable collection of mortgage files to make an internal review worthwhile.
To download the white paper “What’s Next for Credit Union Mortgage Regulation Implementation,” visit http://www.policyworksllc.com/white-papers.cfm.