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which are now called variances. The “zero
percent” and “ten percent” buckets have
changed to ensure that consumers do
not experience any extreme variances in
fees. For builders who also have affiliated
mortgage and settlement operations, the
variances become even stricter.
About Upgrades
Virtually all home builders make
upgrades available to their buyers at time
of purchase. The unfortunate fact is that
buyers sometimes take weeks or months
to make their decisions about these
upgrades. Normally, this is not a problem.
However, upgrades can affect the purchase
price and therefore the loan which can
cause a retriggering of the disclosures and
additional waiting periods. Home builders
will want to make sure they counsel buyers
to make upgrade decisions sooner rather
than later to avoid unexpected delays.
Conclusion
Most builders have partnerships or
affiliations with strong mortgage and
settlement providers who can help
provide insight and information about the
changes to the disclosures and timelines
that will become effective August 1,
2015. Builders must not only determine
the readiness of these partners but also
begin discussions about how the closing
process is changing and what can be done
to ensure that operations and transactions
remain efficient. By partnering with other
industry participants and beginning the
education process now, we can ensure that
both industry and consumers are prepared
for the coming changes.
Marvin holds the position of senior vice president
of business integration and serves as the CFPB
program manager for Stewart. Since joining
Stewart in 2007, Marvin has overseen a wide
variety of compliance, technology, process
improvement and consumer experience initiatives
across the direct, agency and centralized title
divisions. Marvin is a frequent speaker at title,
mortgage and real estate industry events on topics
ranging from CFPB compliance to technology
solutions that improve the consumer experience.
Prior to joining Stewart, he served as chief
information officer for a large, West Coast title
agency, as well as holding strategic technology
positions with other national underwriters. Previous
to entering the title industry, Marvin was in a
management role for a national mortgage lender.
Feature
Of more interest to home builders is
that the Closing Disclosure must be
received by the consumer three full
business days prior to consummation.
Coordination with the lender will
be important given that lenders will
typically be delivering the disclosures.
