The short answer is, “yes.”
The first week in June, the Consumer Financial Protection Bureau (CFPB) responded to a letter from Congress asking for a delay in implementation to the New Year of the new Rule due to take effect August 1st. This has received a lot of interest, so let’s look at it.
The “grace period” that Congress was looking for is not going to happen, but there was a compromise.
The Rule is still going in to effect on August 1st, so everyone still needs to be ready to go. What we have instead of a full-blown “grace period” is a declaration from the CFPB that there will be “sensitivities” towards good faith efforts by service providers to comply with the rule.
That should translate in to a more understanding enforcement framework for an unspecified period of time should there be some challenges by the various parties trying their best to be in compliance.
We may have a little breathing room from fear of full enforcement on day-1, but everyone still needs to make sure they are making every effort to stay in compliance.
What about Watson Title Services of N FL Inc.? We’re ready to go.
One bit of good news that came out last week? The clarification that not all changes in APR will retrigger the 3-day disclosure requirement. Only an increase in APR will.
We hope for more clarification in the next few months, and we’ll keep you up to speed as they emerge.
There will be a transition period as everyone becomes comfortable with the new rule, so the best thing you can do is to make sure you are ready, and we’re here to help you do just that.
Remember to keep an ear out for when I will be conducting training in your office or at Corporate over the summer on the new Closing Disclosure and some of the aspects of the Rule.
If you can’t make it to one of the open sessions at Corporate, go to YouTube and search for “Watson Title Services of N FL.” Click my face, and you’ll be able to see the entire series of training videos that will get you up to speed.
You can get the PDF of this Title Tip here.
My Agent Greg 