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Integrated Disclosures

 

Why existing systems can’t handle new collaboration needs

 

When the CFPB created the new Loan Estimate and Closing Disclosure to replace the HUD-1, GFE and TIL, they didn’t just create new forms. They altered the way lenders must collaborate with workflow participants in order to meet the requirements stipulated by the new integrated disclosures regulations. If you’re a lender and you’re counting on enhancements to your existing systems to support the new compliance standards, you are likely underestimating the challenge ahead of you.

 

 

It’s not just a content question. It’s where the content comes from.
Successful implementation of new requirements may require updates to your existing systems and redesign of your process for creating and sending the new documents. Much of the loan data will need to be remapped and managed to populate the disclosure forms. You’ll need to pull data from multiple systems to generate the new forms, especially the Closing Disclosure. Because the Loan Estimate and Closing Disclosure are designed to work in tandem, you’ll also have to compare fees between different documents to ensure variances are within range. Finally, you’ll need audit trails of the consumer interaction to support TRID compliance.

 

Existing systems of record are too siloed to provide the necessary level of collaboration.

Existing third-party service providers and their disparate technologies may not be prepared to enhance their systems to support these changes. An LOS may have the data but is unable to produce the required documents or get them to the consumer quickly and cost-effectively. A document preparation system may be able to prepare the documents, but is unable to get them to the consumer or audit fee changes over time. Other technology vendors likely don’t provide a complete view from upstream to downstream for you to monitor compliance and quality.

 

Compliance is best achieved through services that are positioned to utilize the output from multiple systems.

The proper solution will easily and effectively leverage the documents and data generated by your existing systems and then utilize their outputs to:

  • Review the data on the Loan Estimate, transfer to the Closure Disclosure, and deliver to consumer within 3 days.
  • Identify and resolve fee variances that are too large; update the documents as necessary.
  • Monitor processes and substantiate compliance when audited.

 

Expedite®

Expedite from eLynx is a suite of integrated on-demand services designed specifically to handle the exchange of documents and data between various systems and workflow participants. With Expedite, lenders can address the following needs around Integrated Disclosures:

 

Loan Estimate

  • Generate and/or compare title, inspection, transfer tax, and recording fees
  • Review and approve the total set of fees for the Loan Estimate
  • Generate the Loan Estimate document for the loan file and optionally provide to brokers
  • Within 3 days of application, electronically deliver and track acceptance of the Loan Estimate by the consumer
  • Collect proof of delivery for the Loan Estimate or print and mail the document

 

Closing Disclosure

  • Collaborate with settlement professionals to approve fees for closing
  • Review and approve the total set of fees for the Closing Disclosure
  • Generate the Closing Disclosure document for the loan file and provide copies to settlement professionals
  • No less than 3 days prior to closing, electronically deliver and track acceptance of the Closing Disclosure by the consumer
  • Collect proof of delivery for the Closing Disclosure or print and mail the document
  • Retain a copy of the delivered Closing Disclosure for 5 years

 

Quality and Compliance

  • Evaluate lender-specific, regulatory, and loan quality directives throughout the loan process and generate alerts when issues or exceptions are detected
  • Track required consumer and compliance events on a shared calendar
  • Receive notifications when required compliance events are approaching
  • Generate a compliance audit report for the loan identifying all events and when they occurred
  • Retain copies of compliance evidence for a minimum of 3 years
  • Establish a baseline of fees and documents approved for closing to prepare for automated post-close reviews


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