Big news last week. There won't be a delay in the August 1st deadline, but there will be a grace period on enforcement. HousingWire has a write up on it where they say Richard Cordray informed David Stevens CEO of the MBA that there will be a delay in enforcement.
Stevens said the industry reached a consensus on the grace period rather than altering the implementation date, which had mixed reviews. He spoke about third party vendors like title companies who all need to alter their integrations. He expects a minimum length through 2015.
The Capsilon Corp, in a survey, recently found 41% of mortgage lenders say they're not going to be ready. The April ABA's survey numbers were bleak, with 79% of the banks not able to verify a delivery date of a new software update. Clearly SoftPro doesn't write LOS software, they released in April.
From what I gather, Cordray will remain the dictator in chief, holding the actual length of the grace period close to the vest. At least for now.
Now what that means as far as opening orders and what they close under, I think that remains up in the air. Currently I'll recommend if your software supports it, then use the CDF when appropriate. If you're not yet upgraded, close it on a GFE HUD while respecting the new TILA rules as is possible. The new 3 day rules apply, whatever disclosures and information apply. I'd also create a simulation of Page 5 of the CDF as an informative sheet for the borrower. Give them the website and all the contact information include anything to show your good faith effort to inform and properly handle the consumer.
I am not a Lawyer, but a disclosure stating something like due to system concerns this order was closed on a GFE HUD, with the TILA rules being followed as much as possible given the technological shortcomings might be warranted. It will be an opaque time. The letter Rick wrote is here.