SDFs... Round 2!
Round 2 of the CFPB's proposed SDF forms was released today. You can access the forms at CFPB's website for the next week or you can always have access to them here at RESPAReady. The CFPB asks you to think about how you would present these forms at closing to a consumer. We would also ask you think about how you would complete these forms and what additional information you would need to do them comprehensively. How would you handle disbursement from these forms? How significant of a change to your software would be required to fill in the information that is new? How about having the TILA calculations on the final settlement form? Could you produce this form 3 days before closing and present it to the consumer without changes at settlement? How would you train your staff to complete and explain these forms? Do you think that showing key loan term information on the SDF will result in a smaller loan package or will these just be duplicate information in one place? If it is just more information on one form, do you think that will be educational for consumers or cause greater confusion? Where would you show charges that are part of a sale transaction that aren't related to a loan (the 1300s section on the current HUD-1 form)? And how many of your reports, invoices, accounting items or other documents looks to existing HUD-1 line numbers that would need to be rebuilt if the proposed new section and line numberings are adopted?
It's time to put critical thought to these forms, vote for a favorite but more importantly add your comments on some of these other issues (and any more than concern you). Remember, you only have one week to vote and comment - Ready, Set, Tell Them What You Think!