Recently, this question was asked of 17 bankers from different banks: “Are you planning to use a third party to complete the new integrated disclosures and close your home mortgage loans when the new rules take effect on August 1st?’
8 of 17 have said “YES”.
This is a small sample size but if these banks thinking their title companies are going to do this for them, they may be in for a surprise. Tthe banks will be responsible for the combined form and several of our title companies have not committed to performing this new function.
How would your bank answer this question? Is it in for a surprise on August 1st or is it prepared?
Deputy General Counsel