COMPLIANCE UPDATE:BY MICHAEL CHRISTIANS
Is your credit union ready for the final version of the TILA-RESPA Integrated
Disclosure rule? The various changes that are set to go into effect on August
1 could leave you scrambling to keep up. This four-stage implementation
plan will prepare you to seamlessly put this new rule into practice at your
Number 1 on every credit union’s mortgage compliance to-do list this summer is addressing the final TILA-RESPA Integrated Disclosure rule, which goes into effect on August 1, 2015. The rule aims to integrate the various disclosures required under the Truth in Lending Act (TILA) and the Real Estate Settlement Procedures Act (RESPA). It also attempts to simplify language the Consumer Financial Protection Bureau (CFPB) has characterized as confusing for would-be homebuyers.
The final rule was published by the CFPB on November 20, 2013, which allowed for a roughly 20-month implementation period. Let’s take a look at the most significant changes imposed by the new rule.
Application Definition & Cure Period Changes
The definition of a mortgage application changed under the Integrated Disclosure rule. Specifically, it was pared down to include six (vs. seven) components. Once a credit union is in possession of those six pieces of information, it must provide applicants with the new loan estimate disclosure within three business days.