Transcription of TILA-RESPA Integrated Disclosure
1 TILA-RESPA Integrated DisclosureGuide to the Loan Estimate and Closing Disclosure formsDecember 2017 Consumer FinancialProtection Bureau This guide is current as of the date set forth on the cover page. It has been updated to reflect the 2017 TILA-RESPA Rule. It has not been updated to reflect the 2018 TILA-RESPA Rule. An updated version will be posted when it is available. 2 TILA-RESPA Integrated Disclosure | VERSION Version logThe Bureau updates this guide on a periodic basis to reflect finalized clarifications to the rule which impacts guide content, as well as administrative updates.
2 Below is a version log noting the history of this document and its updates: DateVersionRule ChangesDecember to incorporate the July 2017 final rule, including changes and clarifications on: The Loan Estimate in the General requirements , General Information, Loan Terms, Projected Payments table, Costs at Closing, Loan Costs and Other Costs, Calculating Cash to Close table, Alternative Calculating Cash to Close table, Comparisons, and Confirm receipt . The Closing Disclosure in the General requirements , General Information, Costs at Closing table, Other Costs, Calculating Cash to Close table, Summaries of Transactions, Borrower s Transaction, Seller s Transaction, Escrow Account, Loan Calculations, and Confirm receipt .
3 Coverage of closed-end credit transactions secured by a cooperative unit in various sections of the , includes changes to Revised Loan Estimate (Section ) and other miscellaneous administrative changes. October to incorporate guidance from existing webinars and guidance, including additional clarification on: The Loan Estimate in the General Information, Loan Terms, Projected Payments Table, Loan Costs, Other Costs, Adjustable Payment Table, Adjustable Interest Rate Table, Contact Information, and Other Considerations sections. The Closing Disclosure in the General Information, Projected Payments Table, Loan Costs, Other Costs, Loan disclosures , Escrow disclosures , and Other disclosures , miscellaneous administrative TILA-RESPA Integrated Disclosure | VERSION DateVersionRule ChangesJuly Changes to bring guide into alignment with Final Rule issued 7/21/2015 and other technical correctionsJanuary 20151.
4 2 Permits certain language related to construction loans for transactions involving new construction on the Loan Estimate (Section Other Considerations)September Updates to information on who to contact with questions on the rule (Section ) Clarification of description of time periods less than whole years (Section Loan Terms) Clarification of requirement relating to provision of appraisals for certain loan types. (Section Other disclosures )April Document4 TILA-RESPA Integrated Disclosure | WHAT S INSIDE What s insideVersion log.
5 21. Introduction .. What is the purpose of this Guide? .. Who should read this Guide? .. Where can I find additional resources that will help me understand the TILA-RESPA Rule?..102. Loan Estimate .. General requirements .. Issuance and Delivery .. Revised Loan Estimate .. Use of Compliance Guide .. Rounding .. Consummation .. Loan Estimate (page 1) .. General Information .. Loan Terms .. Projected Payments .. Costs at Closing .. Loan Estimate (page 2) .. Loan Costs .. Other Costs ..425 TILA-RESPA Integrated Disclosure | WHAT S INSIDE Calculating Cash to Close.
6 Alternative Calculating Cash To Close Table for Transactions Without A Seller or For Simultaneous Subordinate Lien Loans .. Adjustable Payment (AP) Table .. Adjustable Interest Rate (AIR) Table .. Loan Estimate (page 3) .. Contact Information .. Comparisons .. Other Considerations .. Servicing .. Confirm receipt ..653. Closing Disclosure .. General requirements .. Issuance and Delivery .. Corrected Closing Disclosure .. Use of Compliance Guide .. Rounding .. Consummation .. Closing Disclosure (page 1).
7 General Information .. Loan Terms .. Projected Payments .. Costs at Closing .. Closing Disclosure (page 2) .. Loan Costs .. Other Costs .. Closing Disclosure (page 3) ..836 TILA-RESPA Integrated Disclosure | WHAT S INSIDE Calculating Cash to Close .. Alternative Calculating Cash to Close Table For Transaction Without a Seller or for Simultaneous Subordinate Lien Loans .. Summaries of Transactions .. Borrower s Transaction .. Seller s Transactions .. Closing Disclosure (page 4) .. Loan disclosures .. Partial Payments.
8 Escrow Account .. Adjustable Payment (AP) Table .. Adjustable Interest Rate (AIR) Table .. Closing Disclosure (page 5) .. Loan Calculations .. Other disclosures .. Contact Information .. Confirm receipt ..1124. Where can I find a copy of the TILA-RESPA Rule and get more information about it? ..1137 TILA-RESPA Integrated Disclosure | INTRODUCTION 1. IntroductionFor more than 30 years, Federal law required lenders to provide two different Disclosure forms to consumers applying for a mortgage. The law also generally required two different forms at or shortly before closing on the loan.
9 Two different Federal agencies developed these forms separately, under two Federal statutes: the Truth in Lending Act (TILA) and the Real Estate Settlement Procedures Act of 1974 (RESPA). The information on these forms was overlapping and the language inconsistent. Not surprisingly, consumers often found the forms confusing. It is also not surprising that lenders and settlement agents found the forms burdensome to provide and Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act) directed the Consumer Financial Protection Bureau (Bureau) to integrate the mortgage loan disclosures under TILA and RESPA sections 4 and 5.
10 Section 1032(f) of the Dodd-Frank Act mandated that the Bureau propose for public comment rules and model disclosures that integrate the TILA and RESPA disclosures by July 21, 2012. The Bureau satisfied this statutory mandate and issued proposed rules and forms on July 9, 2012. To accomplish this, the Bureau engaged in extensive consumer and industry research, analysis of public comment, and public outreach for more than a year. After issuing the proposal, the Bureau conducted a large-scale quantitative study of its Integrated disclosures with approximately 850 consumers, which concluded that the Bureau s Integrated disclosures had on average statistically significant better performance than the preexisting disclosures under TILA and RESPA.