Things you need to know about the new rules within the Mortgage Disclosures Rule
Back in 2010 The Dodd-Frank Act mandated the combination of the Truth in Lending Act (TILA) loan disclosures with Real Estate Estimate and HUD-1 settlement statement disclosures.
How Will This Happen: The Consumer Financial Protection Bureau an entity created by the Dodd-Frank Act, issued a new TILA final regulation that, among other things, created two new forms (each with many variations) and new 3 business day delivery requirements.
- Loan Estimate – 3 business days after application
- Closing Disclosure – 3 business days before consummation
Impacts on Real Estate
- Closings may take longer because of the 3 business day review periods
- You’ll be seeing different forms for most transactions.
- Your contact information and license number must appear on the Closing Disclosure form.
- Clients could receive multiple loan estimates due to:
- “Changed Circumstances” – certain defined circumstances that cause the estimated changes to increase by more than the variance allowed under the final rule:
- multiple applications with different lenders or multiple applications for different loan products with the same lender
- Your clients may receive multiple Closing Disclosures:
- Some with a 3 day business day waiting period and some without; and
- Some before closing and some after
- Some with a 3 day business day waiting period and some without; and
For more information about the Integrated Mortgage Disclosures Rules, leave a comment, or feel free to contact us!
