Looks as though Wells Fargo, one of the nation’s biggest lenders, has decided they will do this in house (Read Here). Hopefully, you are aware that for loans originated as of August 1, 2015 (nine months from now) you will be required to provide the consumer with a new Closing Disclosure (which replaces the final TIL and HUD 1) no less than 3 business days prior to the closing.
If you’re not aware, you had better do some digging and find out about the new rules (Rules). BTW – these also require a new Loan Estimate disclosure within 3 business days of application (which replaces the initial TIL and GFE). More programming and training required.
Now you need to decide who will provide the new required Closing Disclosure to your borrowers; you or the closing agent. It can be either, but you, as the lender, are held responsible and accountable.
It looks as though Wells decided that if they are going to be on the hook, they want to take control of the process and ensure it is done correctly and in a timely manner. What are your plans?
If you do it in house, you need the systems in place to gather all the info needed for the closing so the disclosure can be provided timely. If you leave it to the closing agent, you’ll need a way to coordinate with each agent closing your loans to provide them with your loan and fee data in time for them to generate the disclosure in your name. All this will require that you a way to ensure it is done on time and it is properly documented. Either way, the loan closing process will change in the near future. Are you ready?