It’s just before closing, a new disclosure is due,
To allow the consumer, an amble review.
The fees need be listed in each Section with care,
With loan costs reflected to allow for compare.
What had been presented in disclosures sent prior,
Now, must be updated for both Seller and Buyer.
All terms of the loan made clear and concise,
The information provided must be precise.
No deviation allowed from the rules of construction,
This Closing Disclosure must be done to perfection.
Now Realtor, now Attorney and Agent and Lender!
On LO, on Underwriter and Closer and Vendor!
All working together to provide what is needed,
To service the consumer, with rules being heeded.
So each lender must be ready with systems in place,
To meet the new challenges from TRID all will face.
Don’t wait ‘til last minute to scurry and run,
Be proactive in doing what needs to be done.
The outlook looks good for new mortgage lending,
With home values up and the economy mending.
So I wish you all joy, good tidings and cheer,
For a very Merry Christmas and a Happy New Year!
Michael L. Vitali – Independent Consultant to the Mortgage Industry
Mike Vitali is an independent consultant to the mortgage industry on matters concerning compliance and mortgage lending. He most recently served as the Senior Vice President and Chief Compliance Officer for LoanLogics, monitoring regulatory developments and their practical implications for the mortgage lending industry. His duties included research, interpretation, and analysis of existing and proposed legislation related to the industry in support of recommendations for policy and/or procedure changes to maintain continued quality and compliance with all applicable laws, rules and regulations, investor requirements, and standard mortgage practices. In his more than 40 years in the mortgage industry, in senior level management, he has gained experience in all areas of mortgage lending, risk management, and compliance.
Mike is a past President of the MBA of Greater Philadelphia, is a charter member and was the second Chairman of the MBA of Pennsylvania, and a past board member and Legislative Chair of both associations. He is a recipient of the 1998 Mortgage Banker of the Year Award from the MBA of Greater Philadelphia, and the 2003 Chairman's Award from the MBA of PA, and currently serves on several compliance related task forces for MBA.
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