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Washington
TILA-RESPA integrated disclosures: A CFPB small-entity guide
WASHINGTON (4/1/14)--An overview of the upcoming Truth-in-Lending Act/Real Estate Settlement Procedures Act rule, and details on "issues that small creditors, and those that work with them, might find helpful to consider when implementing the rule," are included in a new Consumer Financial Protection Bureau guide.
 
In the guidance, the CFPB notes that financial institutions may want to review their processes, software, contracts with service providers, or other aspects of business operations in order to identify any changes needed to comply with the rule.

"Changes related to this rule may take careful planning, time, or resources to implement," the CFPB said. The TILA-RESPA rule goes into effect Aug. 1, 2015.
 
Areas addressed in the guidance include:
  • The loan-estimate disclosure;
  • Delivery of the loan estimate;
  • Good faith requirement and tolerances;
  • Revisions and corrections to loan estimates;
  • Timing for revisions to loan estimate;
  • Closing disclosures;
  •  Practical implementation and compliance issues;
  • Delivery of closing disclosures; and
  • Revisions and corrections to closing disclosures.
The rule features integrated mortgage disclosures under Regulation X and Regulation Z, and provides a detailed explanation of how the forms should be filled out and used.
 
For the full CFPB guide, use the resource link.
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