The ever changing regulatory environment within the real estate industry has dramatically altered the way real estate and mortgage professionals evaluate new products and technologies. RatePlug continues to grow our market footprint across the Country, supporting over 600,000 agents in over 50 of the largest MLS organizations. Our list of participating banks, credit unions and lending companies now exceeds 800 entities. Each of these lending companies has evaluated and approved the RatePlug Program as compliant. In addition, RatePlug has enlisted the services of K&L Gates, the leading compliance experts in the Country to validate our Program's adherence to all regulatory guidelines.
Specific details pertaining to regulations:
RESPA-TILA: RatePlug contracts with the local MLS organization to add the RatePlug Program to their core services provided to their Agent members for which the members pay membership dues. The lender pays RatePlug a license fee to be displayed within the system. There are no fees being paid by Lenders on behalf of agents and there is no mention or criteria for leads to be contingent on affiliation. The real estate agent can display multiple lenders as well.
FTC MAP: The FTC implemented requirements regarding Mortgage advertising. The Mortgage Acts and Practices (MAP) regulations impact ALL real estate professionals offering information about mortgages to clients or customers. RatePlug has taken the following steps to protect the Broker/Agents:
Record Keeping - The regulations specify that real estate professionals are required to save all mortgage related communications for up to 6 years (RatePlug actually stores for 10 years) from the date that the communication was made available to the consumer. RatePlug archives every lender display created on property reports as well as every property flyer generated through the RatePlug system for retrieval at a later date if necessary.
Disclaimer language- RatePlug has adopted the National Association of Realtor's recommended disclaimer and has incorporated the language into all flyers generated through our Program. This disclaimer is simple and clear specifying that the Broker/Agent is not a mortgage lender and directs the customer to contact the lender directly with mortgage related inquiries.
REG Z: The foundation of the RatePlug Program was based on the aggregation and display of accurate rates, APR's, and disclaimers within our presentation layer. The participating lender inputs and controls all the rate and program information that will be displayed. Our development team has painstakingly made every effort to ensure that all REG Z guidelines are met and exceeded. Kirkpatrick & Lockhart have orally expressed that the RatePlug Program is compliant with REG Z guidelines. In addition, we receive scrutiny from each lender that participates in our Program. We have national approval from some of the largest lenders. Each Lender is able to customize all disclosure information within our system as a further safeguard.
TRID: RatePlug will be adding a second page to our property flyers to include the required payment chart (sample below)
RatePlug's legal advisors and vast network of national lenders ensures that we are aware of the latest regulatory rulings, and our team of developers work diligently with these entities to adjust our RatePlug Program to seamlessly implement any changes that would impact our subscribers.