Although the TILA-RESPA Integrated Disclosure rule does not take effect until August 1, 2015, and creditors actually cannot use the new forms until that date, many financial institutions are seeing a barrage of publications from the CFPB regarding the new form. Recently, the CFPB published another “small entity compliance guide” that is geared to assist smaller financial institutions with the necessary steps to comply with the final rule. The format of this guide is question-and-answer, and it cites to the specific regulatory sections that correspond with each aspect of the compliance puzzle. Financial institutions and lawyers assisting with regulatory tasks should review this document.
However, please take note that for applications received prior to August 1, 2015, creditors must follow the existing requirements under Regulations X and Z, and use the existing forms: Truth-in-Lending disclosures, Good-Faith-Estimate, and HUD-1 Settlement Statement.
Should you have questions, please contact Spilman or other knowledgeable counsel.