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Publisher: Matthew Bender Elite Products
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Publication Information:
The Mortgage Lender's Guide to the 2015 Truth-in-Lending Act and RESPA Disclosure Integration Rules: Pub number 01912 Print or eBook
Background:
On November 20, 2013, the Consumer Financial Protection Bureau approved the TILA-RESPA Disclosure Integration Rule (DI Rule). The DI Rule combines and integrates the disclosure forms that consumers receive when they apply for closed loan mortgages (mortgages that don't allow prepayment). The new DI Rule amends Regulations X, the Real Estate Settlement Procedure Act and Regulation Z, the Truth-in-Lending Act.
Who Needs Information About the New DI Rule?
Lenders and mortgage brokers of closed end mortgages will need to shift all of their consumer residential mortgage loan applications to the requirements of the DI Rule on October 3, 2015. This is a critical and mandatory deadline. Until October 3, 2015 lenders must continue providing the current forms (e.g., Good Faith Estimates and Truth-in-Lending Disclosures). For loan applications received on or after October 3, 2015, however, lenders must provide Loan Estimates and Closing Disclosures. Lenders must have their new forms and procedures ready to go on October 3, 2015.
Is the New DI Rule Just About Some New Forms?
No. The DI Rule does more than just combine application and closing disclosures. The DI Rule provides very specific instructions - which must be complied with - on how to complete Loan Estimates and Closing Disclosures. The DI Rule also affects policies and procedures beyond disclosure integration, including:
• a new escrow closing notice requirement before many escrow accounts can be closed;
• new disclosure requirements when ownership of a loan changes
• new guidance requirements related to buydowns
• new simplified disclosure of prepayment penalties
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