Important Updates to TILA-RESPA Integrated Disclosure Rule

Over the last few weeks, the Consumer Financial Protection Bureau (“CFPB”) has issued several important notices that financial institutions need to review and understand. Most importantly, the CFPB proposed new substantive amendments to the TILA-RESPA integrated disclosure rule issued in November 2013. You will recall that the integrated disclosure effective date is August 1, 2015. The CFPB describes the two major proposed changes as follows: (1) to relax the timing requirement that creditors provide revised disclosures on the same day that a consumer’s rate is locked, in order to give creditors until the next business day to provide a revised disclosure; and (2) to place language relating to certain new construction loans on the Loan Estimate form. You can review the proposed amendment here.

Also in reference to the TILA-RESPA integrated disclosure rule, the CFPB published an updated mortgage Readiness Guide to include the new TILA-RESPA integrated disclosure rule. The guide now contains changes to final rules issued through August 1, 2014, covering both RESPA and TILA.

Finally, the CFPB has been taking part in webinars on the TILA-RESPA integrated disclosure rule. The most recent session focused on changes to the Loan Estimate Form, but the archives provide additional content on introductory matters and frequently asked questions. These are valuable tools for a variety of mortgage banking professionals to review.

Please contact Spilman with any questions you may have regarding these resources or the implementation of the TILA-RESPA integrated disclosure rule.

 

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by R. Scott Adams

R. Scott Adams

 

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