The delay in enacting the use of the new disclosures is because at the moment there is nothing in place to allow compliance with the new rules.  As a mortgage broker, I could certainly use the new forms by writing everything in by hand, but there is no way for me to get the data electronically from my loan application software into the new form. 

Although it's not that big of a deal to hand write everything into the new forms, everything is done electronically these days.  We use one software program, Fannie Mae uses another program, the lenders use another one, the doc prep company uses another one, the title company uses another one, etc.  Whenever a change is made, it just takes a while to get all the computer programming done correctly.

Another problem is that the new GFE combines many fees into one fee.  For example, all of the lender fees are now combined, but in many instances, these fees are disbursed to different companies (origination fee goes to the mortgage company, processing fee goes to the processing company, underwriting fee goes to the lender, etc.).  How is that handled?  No one knows yet.

I'd say they have at least a year of work to figure this whole mess out.  HUD has said, "Thie is the way it will be", which is entirely within their rights - they are in charge of it, after all.  But they have not thought about how anyone who is affected by the new rule will be able to conduct business and still remain in compliance. 

If everything was handwritten, there would be no problem.  Stupid computers!  :-)

By the way, wait until you hear the outroar from all the mortgage brokers who now have to disclose how much they make.  We've had a state disclosure in Colorado for a year now that is very close to the new GFE, and everyone went nuts when that was enforced, but no one lost any business.  Realtors have to say how much they get paid -- why not mortgage brokers?  Personally, I kind of like it when borrowers find out that I get paid a lot.  It's a great sales tool for anyone who is good.  It's the old, "you get what you pay for" thing. 

Here's another goof in the new law: we are not allowed to collect any income, asset, etc, info from a borrower until they have chosen a lender, based on the new GFE.  The theory is that once a borrower gives all their info to a mortgage broker, they're going to stop shopping around, so HUD says we can't collect anything.  How the heck can anyone pre-qualify someone if they don't know how much they make?  This will be a HUGE problem for realtors.

As I said, they need at least a year to get this mess straightened out!