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TILA-RESPA Integrated Disclosures

The closing process will significantly change when the Consumer Financial Protection Bureau's fine rule for integrated mortgage disclosures goes into effect. The rule integrates forms required under the Truth-in-Lending Act (TILA) and Real Estate Settlement and Procedures Act (RESPA). A Loan Estimate will replace the current Good Faith Estimate and early TIL disclosure, while a Closing Disclosure will replace the HUD-1 and final TIL disclosure.

The CFPB announced a proposal to push back implementation until Oct. 3, 2015.

Key Documents

Education/Training DVD

ALTA's Land Title Institute has created a training DVD to help you prepare for the disclosures. The DVD includes six modules that will help you understand the disclosures, including an introduction, what led to the development of the new disclosures, a step-by-step explanation of the Loan Estimate and Closing Disclosure, a discussion on how business processes will change, walk through how business relationships will change and how data will be shared, and additional resources and next steps.

A customizable model presentation also is available to guide discussions with your customers.

Order from the ALTA Store or print and complete the order form.

2015 TRID Forum Recording

Purchase a recording of the TILA-RESPA Integrated Forum held in Dallas. The more than seven hours of discussion provides the latest interpretations and rules on the TILA-RESPA integration from the CFPB, addresses implications for closing/settlement, provides information on completing the Loan Estimate and Closing Disclosure, highlights how technology can be used to collaborate and solve compliance issues and explains how the entire real estate transaction will be changed.

Additional Documents and Resources

ALTA Settlement Statement

ALTA developed standardized ALTA Settlement Statements for title insurance and settlement companies to use to itemize all the fees and charges that both the homebuyer and seller must pay during the settlement process of a housing transaction. Four versions of the ALTA Settlement Statement are available. Download here.

Data standards

Freddie Mac and Fannie Mae have released a common industry dataset, called the Uniform Closing Dataset, which leverages and maps to Mortgage Industry Standards Maintenance Organization (MISMO) data standards, to support implementation of the TILA-RESPA Closing Disclosure form.



Follow ALTA’s blog for updates and analysis of the rule, as well as answers to questions about the disclosures that were submitted to ALTA. Sample posts:

Submit Your Questions/Comments about the rule to ALTA here


What You Can Do

Join the Title Action Network to keep up-to-date about the rule and how you can take action.

Report RESPA Violations

If you want to report a possible violation of the Real Estate Settlement and Procedures Act (RESPA), email Include any evidence and contact information so that investigators may contact you. To the extent consistent with law enforcement needs, the Bureau will not disclose your identity and will maintain confidentiality as permitted by federal laws.

News on the Consumer Financial Protection Bureau

November 24, 2015 How to Disclose Simultaneous Issue Rate for Know Before You Owe
Several ALTA members have reported that lenders are unsure how to calculate the owner’s title insurance premium when issued simultaneously with a lender’s policy under the CFPB’s Know Before You Owe (TILA-RESPA Integrated Disclosures) rule. Additionally, situations in which the seller pays for the owner’s title insurance policy on behalf of the buyer, the Cash-to-Close figure on the Loan Estimate and Closing Disclosure will be inaccurate. Read on for guidance on how to disclose simultaneously issued policies and how the CFPB says credits can be used to get the correct cash-to-close figure.
November 24, 2015 TRID Q&A: Should Basic or Enhanced Rate be Quoted for Owner’s Policy?
Does the TILA-RESPA Integrated rule require that the lender disclose the basic rate for owner’s title insurance, as opposed to quoting the enhanced rate?
November 24, 2015 Penalties for Failing to Comply with TRID
The Consumer Financial Protection Bureau has broad authority to enforce compliance with nearly all federal consumer finance statutes. While there’s no clear guidance on whether TILA or RESPA is the dominant statute, penalties can range from $5,000 per day for a violation to $1 million per day for known violations.
November 24, 2015 Lenders Modifying Closing Instructions in Wake of TRID
With lenders responsible for production and delivery of the Closing Disclosure under the TILA-RESPA Integrated Disclosures (TRID) rule, many lenders are modifying their closing instructions and shifting liability onto settlement and closing agents. Because of this, ALTA reminds members to read all lender closing instructions carefully.
November 24, 2015 Requirements for Delivery of the Closing Disclosure
The CFPB provides many details on requirements for production and delivery of the Closing Disclosure. Read on for information about fee disclosure, timing, accuracy, role of the settlement agent, who is responsible to provide the seller with the Closing Disclosure, how to handle multiple consumers and rescindable transactions.
November 24, 2015 Encourage Your Senator to Pass TRID Hold-harmless Bill
Introduced by Sens. Tim Scott (R-SC) and Joe Donnelly (D-IN), S. 1711 would direct the Consumer Financial Protection Bureau to observe a temporary safe harbor for companies working in good faith to comply with TRID until Jan. 1, 2016. On Oct. 7, the House of Representatives passes a similar bill by an overwhelming bipartisan vote of 303-121.
November 24, 2015 Questions About TRID?
Have questions or issues about TRID that you need answered? Send an email to ALTA will address common questions/issues here on its blog.
November 24, 2015 Tolerances with the TILA-RESPA Integrated Disclosures
The CFPB's TRID rule restricts the circumstances in which consumers can be required to pay more for settlement services than the amount stated on their Loan Estimate. In addition, if a lender allows a consumer to shop for a settlement service, the lender will be required to provide the consumer with a written list identifying available providers of that service and clearly stating that the consumer may choose a different provider for that service. Read on to learn more about tolerances and shopping under the new rule, and check out a chart that outlines which fees can and can't change.
November 24, 2015 Download ALTA's Model Settlement Statements to Use for TRID
ALTA has developed four model Settlement Statements for title insurance and settlement companies to use in order to itemize all the fees and charges involved in the transaction once the CFPB's TILA-RESPA Integrated Disclosures go into effect Oct. 3. Settlement statements are currently used in the marketplace in conjunction with the federal HUD-1. The model Settlement Statements are not meant to replace the Consumer Financial Protection Bureau's Closing Disclosure. Bank of America said it encourages settlement agents to use ALTA's model Settlement Statements or similar state-specific forms when needed to supplement the Closing Disclosure.
November 24, 2015 How to Comply with the Closing Disclosure's Three-day Rule
According to the Consumer Financial Protection Bureau’s final rule, the creditor must deliver the Closing Disclosure to the consumer at least three business days prior to the date of consummation of the transaction. While a few national lenders have announced they will handle production and delivery of the Closing Disclosure, not all financial institutions will have the same capability. Read on for guidance to help you determine when the Closing Disclosure should be sent to ensure the buyer receives it three days prior to consummation of the transaction.
More CFPB Articles

For More Information Contact

    Justin B. Ailes
Vice President of Government & Regulatory Affairs
Phone: 202-296-3671 Ext. 215
Contact Me About: Federal Legislative and Regulatory Issues, NAIC

    Steve Gottheim
Senior Counsel
Phone: 202-296-3671 Ext. 230
Contact Me About: Federal Legislative and Regulatory Issues, Legal Issues, Best Practices Inquiries

    Benjamin P. Lincoln
Director of Government Affairs
Phone: 202-296-3671 Ext. 220
Contact Me About: Government Affairs

    Jessica McEwen
Director of Political Affairs
Phone: 202-296-3671 Ext. 233
Contact Me About: Federal Legislative and Regulatory Issues, TIPAC

    S. Madeleine Nagy
Director of State Government Affairs
Phone: 202-296-3671 Ext. 329
Contact Me About: State Government Affairs Issues

    Ashley Sadler
Associate Legislative and Regulatory Counsel
Phone: 202-296-3671 Ext. 239
Contact Me About: Federal Legislative and Regulatory Issues, Legal Issues, Best Practices Inquiries

    Awesta Sarkash
Grassroots & Advocacy Manager
Phone: 202-296-3671 Ext. 212
Contact Me About: Title Action Network (TAN) Inquiries

    Wayne M. Stanley
Director of Public Affairs
Phone: 202-296-3671 Ext. 221
Contact Me About: Homebuyer Outreach Program, Media Inquiries, Social Media, Press Releases, Title Action Network (TAN)

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