09-EF-07: FRB: Regulation Z - Implementing the Mortgage Disclosure Improvement Act

In July of 2008, the Board approved final rules implementing the Home Ownership and Equity Protection Act (HOEPA). The rule required early Truth in Lending Act (TILA) disclosures providing a good faith estimate (GFE) of the cost of mortgage loans. The rule was not limited to purchase loans, but included all non-purchase closed-end loans secured by the borrower's principle dwelling, such as refinance loans. On the same day that rule was published, Congress passed the Mortgage Disclosure Improvement Act (MDIA). The MDIA codified much of the Board's July 2008 rule. However, the MDIA also went further, requiring the same disclosures for loans secured by second homes. Additionally, the MDIA required waiting periods between disclosures and consummation of the loan.