Consumer Financial Protection Bureau
ALTA is Your One-stop Shop for Information on Implementation of the New Closing Disclosure
|September 16, 2014
Implementation of the Consumer Financial Protection Bureau’s integrated mortgage disclosures is Aug. 1, 2015. Note that there is no stagger in the roll out. All mortgage applications prior to Aug. 1, 2015 will use the current Good Faith Estimate, HUD-1 and Truth-in-Lending disclosures. All applications received on or after Aug. 1, 2015 will use the new Loan Estimate and Closing Disclosure. ALTA's Integrated Mortgage Disclosures Task Force has been involved in the process since day one.
ALTA has already developed many tools to help members implement the new disclosures due to the Task Force's active participation. Here’s a sampling of some of the information and resources ALTA has already developed to help members prepare for the August 2015 implementation deadline. More resources will be available going forward.
Go to www.alta.org/cfpb to stay up to date and check out ALTA’s clock counting down the days to implementation.
Here’s a look at several blog posts ALTA has made so far. Have a question? Send it here.
- New Era In Closings Prepare Now for the CFPB's Integrated Mortgage Disclosures: The new rules will require significant and costly systems and process changes to ensure compliance in the new world of closings. Listen to a recording of a 100-minute webinar to learn about some the biggest workflow and process challenges as the industry prepares to transition from today’s HUD-1 and GFE to the Closing Disclosure and Loan Estimate. Who fills out and provides the Closing Disclosure to the homebuyer, the three-day rule, redisclosure, calculating title premiums when policies issued simultaneously, labeling and listing of title fees, these are just some of the issues the webinar will address. Speakers include Cynthia Blair of Rogers Townsend & Thomas, Ben Olson of Buckley Sandler, Mary Schuster of RamQuest and Dan Wold of Old Republic National Title Insurance Co.
To help members get the information they need, we broke up the webinar into different segments.
- Overview of Final Rule: Cynthia Blair of Rogers Townsend & Thomas, and an ALTA board member, provides an overview of the Consumer Financial Protection Bureau's final rule for integrated mortgage disclosures, including applicable loans, the effective date and issues not included in the final rule.
- Liability: Since the Closing Disclosure combines requirements under the Real Estate Settlement Procedures Act (RESPA) and the Truth-in-Lending Act (TILA), there’s questions on which statute trumps the other in regard to liability. Ben Olson of Buckley Sandler talks about the liability issues.
- Loan Estimate: Mary Schuster of RamQuest and Ben Olson of Buckley Sandler explain the three-page Loan Estimate.
- Closing Disclosure Rules: Dan Wold, chair of ALTA's Integrated Mortgage Disclosures Task Force, discusses the CFPB's new Closing Disclosure, which goes into effect August 2015. Wold talks about the three-day rule, who provides the form to the consumer, disclosure of title fees and how to calculate the simultaneous issue price on the form.
- Review of Closing Disclosure Form: Mary Schuster of RamQuest and Cynthia Blair of Rogers Townsend & Thomas, and an ALTA board member, walk through the five-page Closing Disclosure that must be provided to the buyer and the seller.
- Written List of Providers: Cynthia Blair of Rogers Townsend & Thomas, and an ALTA board member, talks about the written list of providers, which is a carry-over from the previous HUD reform.
- Implementation Concerns: Cynthia Blair of Rogers Townsend & Thomas, and an ALTA board member, talks about the various implementation concerns regarding the CFPB's integrated mortgage disclosures, including the possibility of longer closings, substantial technology changes and employee training.
- Next Steps: Mary Schuster of RamQuest and Dan Wold, chair of ALTA's Integrated Mortgage Disclosures, talk about what title professionals should be doing to prepare for the August 2015 implementation of the integrated mortgage disclosures.