Financial Link ® (GulfPak) Mortgage and Loan Pre-Update Notification

This pre-update notification is to make everyone aware that a compliance update will be released on July 22, 2009. You will be notified through your usual channels for availability that day.

This service release should be loaded no later than July 30, 2009 to comply with the statutory and regulatory amendments to Regulation Z that affect coverage, delivery and content requirements of the Estimated Truth-in-Lending Disclosures (Early TIL disclosures) beginning July 30, 2009.

If installed prior to July 30, 2009, users should be aware that the WBA 240C Estimated Truth-in-Lending Disclosure will appear more often due to Regulation Z changes which require Early TIL disclosures for any closed-end credit transaction that is both secured by the consumer’s “dwelling” and subject to RESPA. This means that Early TIL disclosures will be required for a larger number of loans.

The content of the Early TIL disclosures will change with the addition of several items. First, a variable rate example has been included due to the expansion of the types of loans that will require Early TIL disclosures. Second, the late charge section has been revised to accommodate the expanded types of transactions that are covered. Third, the following statement will be required “You are not required to complete this agreement merely because you have received these disclosures or have signed a loan application.” This statement has been added to both the Early TIL as well as the WBA TL241 Truth-in-Lending Disclosure. Finally, the required deposit disclosure has been added.

More information on this can be found in the May issue of the WBA Compliance Journal as well as the FIPCO notice released June 1, 2009 on various compliance changes for 2009-2010.

Any questions regarding this notice may be directed to Software Support at 800/722-3498 or e-mail to fipcosupport@fipco.com. Please include your name, financial institution name and a phone number in all e-mail correspondence.