The Consumer Financial Protection Bureau has published updated versions of the Small Entity Compliance Guide and the Guide to Forms for the TILA-RESPA Integrated Disclosures rule. The Small Entity Compliance Guide was updated to incorporate guidance from CFPB webinars and to add clarity on topics such as the following:
- record retention requirements for the closing disclosure
- completion of the loan estimate and closing disclosure
- formatting of the loan estimate and closing disclosure
- delivery requirements for the loan estimate and the special information booklet
- disclosure and determination of good faith for services the borrower may shop for
- construction loans
Regarding the Guide to Forms, the CFPB added additional information for the Closing Disclosure, including more information on the projected payments table, loan costs and other disclosure sections. The Loan Estimate includes more information about loan terms, the projected payments and adjustable payments tables.
Closing factsheet: An overview of the limited circumstances when changes to the loan require a new three-day review - June 2015
Graph Showing Effect of the 3 Day Delivery Rule - April 2015
Preparing You Now on CFPB - March 2015
Owning a Home Toolkit - provided by Title Company of the Rockies and the CFPB
Owning a Home Toolkit - Spanish Version
Announcing the Title Company of the Rockies ALTA Best Practices Pledge! - February 2014
The Consumer Financial Protection Bureau (CFPB) has issued their long awaited proposed rule (it is a 1099 page regulation by the way) that includes a new settlement statement. So what does this mean? What are the new deadlines for disclosure to consumers? How are tolerances being expanded? And what do the new forms look like? These are just a few of the topics we will touch on as primers and the information being provided below for the reforms being required by the CFPB as called for by Dodd-Frank § 1032(f), 12 United States Code § 5532(f). The new “Loan Estimate” replaces current GFE and initial TIL. It's three pages long. The new “Closing Disclosure” replaces current HUD-1 and final TIL. It's five pages long.
Primer on Owner Financed Real Estate Transactions in Colorado for Sellers, Brokers, and Settlement Agents - May 1, 2014
Guide to Completing TILA-RESPA Integrated Disclosure forms available now - April 17, 2014.
Compliance guide: A plain-language guide to the new rules in a FAQ format which makes the content more accessible for industry constituents, especially smaller businesses with limited legal and compliance staff. March 31, 2014.
Integrated loan disclosure forms & samples: Downloadable Loan Estimate and Closing Disclosure forms in both English & Spanish and samples for different loan types. March 31, 2014.
Mortgage Bankers Association’s Summary of CFPB’s Final RESPA-TILA Integration Rule and associated Forms - November 20, 2013
The CFPB “Know Before You Owe” Fact Sheet - November 20, 2013
CFPB released its final rule on the new Integrated Mortgage Disclosures known as the “Know Before You Owe” - November 19, 2013
It is our understanding that these are some of the rule highlights:
- The implementation date is August 1, 2015.
- There is no mandate the lender prepare and deliver the new Closing Disclosure Form. Lenders are allowed to work with settlement agents on this process.
- "All in APR" did not survive. Title and settlement fees are excluded.
- The events that would require a retrigger of a new 3 day time period have been curtailed. A 3 day retrigger would only occur in the event of: significant changes to APR, changes in the loan product, or the addition of a prepayment penalty.
- Saturdays count as a business day only if the lender is open for business on Saturdays.
- The CFPB says consumers can save money if they shop around for their own service providers for title and settlement services.
- The new Loan Estimate Form and Closing Disclosure Form will be available in English and Spanish versions.
- Click here to link to the CFPB Know Before You Owe fact sheet.
Qualified Mortgage Primer - October 2013
CFPB Finalizes April Clarifications to Mortgage Rules - September 13, 2013
ALTA Announces "Title Insurance and Settlement Company Best Practices" Version 2.0 - August 1, 2013
CFPB Director Acknowledges ALTA Concerns with Three-day Rule - July 15, 2013
This is a central access point for the comprehensive CFPB mortgage-related implementation materials, including mortgage rules at a glance, small entity compliance guides, videos, quick reference charts, 2013 rural or underserved counties list, other helpful materials - June 13, 2013
CFPB finalizes amendments to ability-to-repay rule - May 29, 2013
Small Entity Compliance Guide for the Ability-to-Repay and Qualified Mortgage Rule - April 10, 2013
Primer specifically for Lenders Regarding the New CFPB Rules - March, 2013
CFPB Extends Effective Date for New Disclosures - November 16, 2012
American Land Title Comments to CFPB Proposed Rule - November 6, 2012
Land Title Association of Colorado Comments to CFPB Proposed Rule - November 6, 2012
CFPB New Rules Primer - October 2012
Closing Dislosure Form
Loan Estimate Form
(Click the links above to view each document. The PDF reader is needed to view them.)