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CFPB Mortgage Disclosure Rules: New Requirements and Impacts on the Mortgage Industry

OnDemand Webinar (89 minutes)

Learn the aspects of the rule changes, new forms and how you must stay compliant with these changes.

The Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank) directed the Consumer Financial Protection Bureau (CFPB) to combine the mortgage loan disclosures under the Truth in Lending Act and Real Estate Settlement Procedures Act into integrated disclosures. After many rounds of testing, the CFPB developed an integrated application disclosure called the Loan Estimate and an integrated closing disclosure called, appropriately, the Closing Disclosure. The CFPB also developed an accompanying rule for the new forms. The new forms and rules became effective October 3, 2015. Examine the basic aspects of the rule and the new integrated disclosure forms, and include a tour of the forms, and issues regarding the rule and forms. The topic will highlight changes that will require decisions regarding how companies conduct business, and that will place burdens on staff and systems, and common issues created by the rule that pose challenges for mortgage industry participants. This topic is important for all parties who participate in the residential mortgage loan industry or assist industry participants, including mortgage lenders and brokers, real estate brokers and agents, title companies, escrow and settlement companies, technology companies, document providers and attorneys.

Authors

Richard J. Andreano, Ballard Spahr LLP

Agenda

TILA/RESPA Integrated Disclosure (TRID) Rule Basics

• Scope

• Effective Date and Related Matters

• The New Forms

• Liability

• Regulator and Secondary Market Approach During Implementation

• Current Matters

Pre-Application Limits

• Written Cost Estimate Requirements

• Upfront Fee Limits

• Upfront Verification Limits

Revised Definition of Application

• Implications

Loan Estimate Rules

• Who Provides; Timing and Delivery

• Written List of Providers

• Limits on Increase in Charges

• Ability to Revise Loan Estimate

• Fee Disclosure Approach

Tour of Loan Estimate Form

Closing Disclosure Rules

• Who Provides; Timing and Delivery

• Ability to Revise Closing Disclosure

• Fee Disclosure Approach

• Post Consummation Corrections

Tour of Closing Disclosure Form