Reply To: Comments Regarding Status of Loan Origination Software – 1/10/14 CMG Meeting


Note to the editors note above in the 4th bullet: The CFPB released an interpretive rule on 11/8/13 that allows for a temporary method of compliance with providing the Homeownership Counseling Rules. For a “temporary” fix (specific expiration was not given in the rule) we can comply by providing a specifically worded disclosure that directs the consumer to the appropriate website. The intent of the interpretive rule appears to be to allow loan origination software companies to get their programming complete, so I would not use this alternative method of disclosure if my LOS is capable of generating the list. Here is the link to the interpretive rule: