GSEs Publish Uniform Closing Dataset Delivery Specification
February 26, 2015
Fannie Mae and Freddie Mac on Feb. 24 issued additional guidance to support implementation of the Uniform Closing Dataset (UCD), which is an effort to standardize the underlying data required by the Consumer Financial Protection Bureau’s new Closing Disclosure.
The government sponsored entities (GSEs) have published Appendix I: UCD Delivery Specification, which presents the UCD in MISMO v3.3.0 XML file order. The UCD Delivery Specification will assist lenders in creating the XML file that, in the future, must be delivered to the GSEs at or before loan delivery.
According to the GSEs, the UCD Delivery Specification allows filtering by purchase and non-seller transaction types to clarify data point requirements that may differ, including cardinality, conditionality, conditionality details and implementation notes. Appendix I also provides guidance on the use of XML ARC role structures to link entity and individual information in the "Contact Information" table on the Closing Disclosure. A future update to the UCD Delivery Specification will provide guidance on the XML file structure for handling "split" disclosures — those cases when a purchase transaction Closing Disclosure is presented as separate "Borrower-only" and "Seller-only" forms.
The Closing Disclosure, along with a new Loan Estimate, goes into effect Aug. 1, 2015. For software providers that must update systems to support the new Closing Disclosure, the UCD will take much of the guesswork out of determining which pieces of data go into which spots on the form. In addition to providing a blueprint to populating the disclosures, the UCD will also serve as a standard data format for settlement software and loan origination systems to exchange information about loan costs.
With these new requirements coming, title agents and lenders should take time now to verify that their respective systems can accept electronic information from the other. Lenders, in particular, will likely demand this capability from settlement providers in order to ensure compliance with the three-day rule. Rekeying of data from one system to the other may not be practical under the new rules.
In the coming months, the GSEs will provide more information regarding the UCD collection mechanism and timeline, as well as instructions on how to deliver the UCD to the GSEs. In the meantime, the GSEs expect that lenders will begin to use the UCD in their internal processes and work with their vendors and service providers to use the UCD for data exchange. Title companies that wish to continue doing business with lenders that sell loans on the secondary market, will need to implement the UCD.
At the 2015 Business Strategies Conference, representatives from Fanne Mae and Freddie Mac will provide information regarding the UCD collection timeline and policies.
In April, ALTA will host a webinar on how title professionals can use technology to enhance collaboration and data sharing with lenders in order to complete the integrated disclosures. Watch for registration information.
Contact ALTA at 202-296-3671 or [email protected].