Feature Enhancements in Version 18.2.0.7 Server Patch 4
The Encompass 18.2 May Service Pack Critical Patch 1 (version 18.2.0.7 Server Patch 4) is being released to provide the enhancements described below. These enhancements require updates to both the Encompass Server and users' client machines. The Server Patch is applied to your Encompass Server automatically, while the client-side updates can be controlled manually using the Encompass Version Manager tool. (If the tool has been configured to always apply new releases to users’ computers automatically, users will receive this update upon their initial log in of Encompass following the release.) Both the Server Patch and client-side updates must be applied in order for these enhancements to be available on your system.
Compliance Update
Updates to Redisclosing on the Closing Disclosure Relative to Consummation
Updates have been made in Encompass to support a final rule change in the Consumer Financial Protection Bureau (CFPB) Know Before You Owe (KBYO) limitations on resetting fee tolerances when redisclosing on a Closing Disclosure relative to the consummation date. Previously, the system would allow a lender to use a Closing Disclosure to reset fee tolerances only if the initial Closing Disclosure’s Closing Date was no more than seven (7) business days later than the CD Issue Date (field ID 3977). This period of time has been referred to as a “gap” or “black hole” by industry participants. The final rule, effective as of June 1, 2018, provides that lenders may use the Closing Disclosure to reflect changes in costs if an estimated closing cost was disclosed in good faith, regardless of when the Closing Disclosure was provided relative to consummation. Encompass will apply this updated rule to all loans that have a Closing Date (field ID 748) of 6/1/2018 or later.
Based upon the final rule, Encompass and the Encompass Compliance Service (ECS) have been updated to remove the seven-day requirement from the Closing Disclosure (re-baselining) tests. (Read the ECS May 2018 Critical Patch release notes for more information.) Encompass and the ECS continue to require that the Initial CD Sent Date (field ID 3977) or Revised CD Sent Date (field ID 3979) cannot be more than three business days after the Changes Received Date in order for the initial or revised Closing Disclosure to reset fee tolerances. Additionally, if the increase in fees causes the APR to become inaccurate, Encompass and ECS continue to require that the revised CD be received by the consumer no later than three business days prior to consummation.
To support the new rule change, a new Use CD to Rebaseline Data option has been added to the Policies category in the Settings Manager in the Encompass Admin Tools. The setting is set to 06/01/2018 by default. Administrators can adjust the setting to a later date, but cannot set it to a date earlier than 06/01/2018.
To Adjust the Use CD to Rebaseline Data Setting
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On your Windows task bar, click the Start menu or Start icon, navigate to the Ellie Mae Encompass program folder, and then click Admin Tools.
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Double-click Settings Manager.
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If you are prompted to log in to the server, type the User ID, Password, and Server that you use to log in to Encompass as the Admin user.
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Select Policies from the Category list.
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Double-click the date in the Value column for Use CD to Rebaseline Date option, select the appropriate date, and then click OK.
CBIZ-17342
