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CFPB clarifies TILA/RESPA closing disclosure and review
CFPB yesterday updated its blog to clarify the three-day review period for closing disclosures under the new TILA/RESPA rules that take effect Aug. 1 and the limited circumstances that could trigger one more review.
The new rule will go into effect on Aug. 1 under the Truth in Lending Act and Real Estate Settlement Procedures Act. In the blog post, CFPB Office of Regulations Managing Counsel Diane Thompson said the new mortgage disclosures will only delay closing for a minority of consumers. "If there is a change to any one of three, very specific, and very important items, the lender must give you another three business days to review the updated disclosure."
The three changes – meaning changes from information provided in the loan estimate – that could trigger a new three-day review period include:
- an increase in the annual percentage rate, or APR, of more than 1/8 of 1 percent for fixed-rate loans and more than 1/4 of 1 percent for adjustable loans;
- addition of a prepayment penalty; or
- change in the loan product (for example, from a fixed-rate to an adjustable-rate loan).
Thompson explained that other changes in the days before closing would not require delays; these might include typos on the forms, problems discovered during walk-throughs and most changes to payments.
NAFCU's compliance team has compiled a list of resources including a series of blog posts and video training modules explaining the new rule.
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