September 24, 2014

Wells Fargo Announces Plans for the New CFPB Closing Disclosure Forms

Who will prepare and deliver the forms and how the process will change

Wells Fargo has announced how it will proceed under the new CFPB Closing Disclosure that will become effective in August of 2015.  In a communication to settlement agents, Wells Fargo has answered some long awaited questions from the title industry including: "Who will prepare the Closing Disclosure? Who will deliver the Closing Disclosure? How will processes change to enable delivery of the Closing Disclosure to the customer for receipt at least three business days prior to closing?"

Read Wells Fargo’s full announcement here.

Who Fills Out the Form?
On the question of "who fills out the form?" the communication states, "...after assessing all requirements and options, it has been determined that Wells Fargo needs to control the generation and delivery of the borrower's Closing Disclosure to consistently meet internal compliance and regulator expectations."

Conducting the Closing
Regarding conducting the closing, Wells Fargo emphasizes the role of the closing agent by stating that “Conducting the closing will continue to be the responsibility of the settlement agent, but with increasing focus on compliance with our closing instructions.”

TLTA will continue to work with the lending community to help facilitate communication between our respective industries as we move towards implementation of the new form.  If you have any questions please contact Aaron Day at aaron@tlta.com or 512.472.6593