Furthermore, while the SERs identified potential upfront and ongoing training costs as a result of the
proposals under consideration at the time, the Bureau believes efforts to train small entity staff on the updated software and compliance systems will reinforce existing professional skills, rather than require staff to acquire skill sets above those needed in the ordinary course of business, and to comply with HUD's 2008 Final RESPA Rule (which, as discussed above,
significantly overhauled the design and content of the RESPA GFE and settlement statement disclosures given to consumers).