CFPB Releases Guide to Complete Integrated Mortgage Disclosures
|April 22, 2014|
The Consumer Financial Protection Bureau has released a 96-page guide that includes instructions on how to complete the new three-page Loan Estimate and five-page Closing Disclosure.
A new five-page Closing Disclosure will replace the HUD-1 and final Truth-in-Lending (TIL) disclosure, while a three-page Loan Estimate will replace the GFE and early TIL. The final rule and new disclosures apply to most consumer mortgages, but does not apply to commercial transactions, home-equity lines of credit, reverse mortgages, or mortgages secured by a mobile home or by a dwelling that is not attached to land. The new forms go into effect Aug. 1, 2015.
The guide, titled "TILA-RESPA Integrated Disclosures: Guide to the Loan Estimate and Closing Disclosure," provides a line-by-line description and highlights common situations that may arise when completing the forms.
The guide is recommended for any organization that originates closed-end residential mortgages, as well as settlement service providers, software providers and other companies servicing as business partners to creditors. However, it should be noted that the CFPB states that the guide summarizes instructions for completing the forms but is not a substitute for the RESPA-TILA rule.
“Only the rule and its Official Interpretations can provide complete and definitive information regarding its requirements,” the CFPB said.
The Official Interpretation of the final rule includes detailed explanations of many of the rule’s requirements. These explanations are found after the text of the rule and its appendices. The interpretations are arranged by rule section and paragraph.
In March, the CFPB released an 89-page compliance guide to provide an easy-to-use summary of the TILA-RESPA rule and highlight issues that small creditors, and those that work with them such as settlement agents, might find helpful to consider when implementing the rule. The CFPB said that the Compliance Guide along with the guide for integrated disclosures should be helpful in determining compliance obligations.
If you have a specific question regarding the rule, you may submit ALTA a question here. Follow ALTA’s blog for answers to common questions.
For more information, contact Steve Gottheim or call 202-261-2943.