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The Fine Art of Due Diligence

July 01 2015

reconis1On June 24th of this year the Consumer Financial Protection Bureau (CFPB) proposed a two-month extension of the effective date of its "Know Before You Owe" mortgage rules. The proposal, if approved by the agency's internal processes, will extend the effective date of the rules to Saturday, October 3rd. The rules, also known as the TILA-RESPA Integrated Disclosure rules, require easier-to-use mortgage disclosure forms that clearly lay out the terms of a mortgage for a homebuyer. The RESPA rules (circa 1974) speak for themselves.

The news of the extension was met by the real estate industry with a number of responses. A significant segment within the industry didn't notice it at all, choosing to ignore the rules as they have done from their initiation some two years ago. Another segment within the industry simple elected to ignore the notice. Finally there is that segment that realizes that these rules will have a significant impact upon their businesses, but are as of yet, uncertain what actions to take.

This piece is directed to this last group. If, after all of the information, commentary, and "wake up" calls that have been distributed, a brokerage firm or its management team still believe that the new rules will have no impact, then the foundations of one amazing surprise have been laid. Try not to gasp when you see the amount of the fine.

The following information is provided for those brokerage executives and managers who recognize that they must take some action, and soon, to avoid a regulatory catastrophe.

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