Plain and Simple: if you weren’t already aware, the CFPB is looking to combine TIL and RESPA disclosures into one document. Home loan disclosures are being redesigned, again! READ MORE

Interesting timing for such a major change isn’t it. A necessary evil, but still interesting timing. These updates are moving forward regardless of the fact that no real clarity has been offered on the future of the housing finance mechanism (GSEs). And even more closely related to the disclosure updates themselves, the industry is attempting to reform its entire compensation model right now. How can we expect lenders to interpret and implement new originator compensation models without knowing how the new consumer disclosure package will look? How can we expect lenders to keep the mortgage market competitive if we don’t have a clear indication of how loans will be securitized. I can go on and on here…HOW ABOUT THE RISK RETENTION REGS? WHAT IS CONSIDERED A QUALIFIED LOAN?

I don’t have a problem with the abundance of reforms that have been outlined for the mortgage industry, but maybe we should approach one major reform at a time to ensure we get the job done right.  Compliance folks can only be spread out so far before their oversight wears thin. 

The final compensation rules are effective April 1,