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an XML UCD file along with a copy of
the Closing Disclosure in a Portable
Document Format (PDF).
For the first year, the GSEs will require
submission of borrower data only. In
other words, lenders must submit a PDF
copy of either the combined Closing
Disclosure or, if a bifurcated approach
is used, the buyer’s form along with an
XML file containing the corresponding
UCD data. Beginning in third-quarter
2018, the GSEs will require submission
of both the buyer’s and seller’s forms
and associated UCD data.
The GSEs are encouraging lenders to
begin submitting both borrower and
seller data well in advance of the 2018
mandate to test their processes. Collaboration platforms that support the latest
MISMO data standards, upon which UCD
is based, can make GSE data delivery
easy through the use of built-in import
and export tools for the UCD XML file.
To date, the CFPB has done only limited auditing of loan-originator compliance with the Know Before You Owe
consumer-disclosure rules. But with initial UCD enforcement around the corner
and the requirement to disclose seller
liabilities coming hard on its heels, it could
be only a matter of time before we begin
seeing stricter regulatory enforcement.
n n n
Many mortgage originators are already
frustrated by the added time and cost
associated with a bifurcated Closing
Disclosure process. Those who choose
to ignore the nagging symptoms of
process inefficiency will only feel the
pain intensify after UCD enforcement.
Making the investment in real-time
collaboration can provide immediate
relief for a problem that’s not likely to
go away any time soon. After all, the
GSEs have communicated no intention
to restrict the use of a separate seller’s
form. With the right technology, loan
originators and settlement agents can
work on their separate forms in lock-step, limiting their compliance risk and
ultimately enabling a faster and less-expensive closing and post-closing
Real-time notifications that alert both
parties when a change is made to either
form can eliminate the compliance risk
of mismatched forms and ensure disclosures are reissued to both borrower
and seller in a timely fashion.
In this scenario, the settlement agent
can feel confident that the seller’s private information is protected, because
coordination with the mortgage originator is clear and documentable.
The originator, in turn, benefits from
reduced compliance risk and a more
streamlined disclosure process that
eliminates extra post-closing effort and
The same technology that enables
loan originators and settlement agents
to collaborate on Closing Disclosures
in real time also will make it easier for
lenders to furnish Uniform Closing
Dataset (UCD) data to government-
sponsored enterprises (GSEs) Fannie
Mae and Freddie Mac in the required
Extensible Markup Language (XML)
format. Effective Sept. 25 of this year,
both GSEs will require lenders to submit
<< Disclosure continued from Page 66 “Many mortgage originators are already frustrated
by the added time and cost associated with a
bifurcated Closing Disclosure process.”