NAFCU highlights key TILA/RESPA measures
Dec. 31, 2013 – A new NAFCU Final Regulation, posted online Monday, highlights the most important implications of CFPB’s final rule on integrated mortgage disclosures under the Truth in Lending and Real Estate Settlement Procedures Acts.
NAFCU’s Final Regulation explains the rule’s requirements regarding a loan estimate, the integrated TILA-RESPA disclosure that lenders must provide borrowers within three business days after receiving an application. A closing cannot occur within seven business days after the loan estimate is provided except in limited circumstances invoked by the borrower.
The rule also requires that a closing disclosure be provided at least three business days before closing, unless the borrower waives this period in certain emergency situations.
The final regulation details the meanings of key terms such as “application” and “business day” in the context of the CFPB’s final rule. It also lists prohibitions on increases in specific estimated charges and fees at closing.
Aspects of the disclosure protocol that the bureau’s final rule does not change include the current requirement to provide a borrower with the Special Information Booklet, and the current definition of “finance charge” under Regulation Z. NAFCU strongly advocated against changing the definition of “finance charge,” which would have impacted the manner that lenders calculate the APR of a loan.
The TILA-RESPA final rule will be effective on Aug. 1, 2015. NAFCU is planning webcasts and other educational materials that will be offered to members throughout 2014 and beyond on this final rule.
NAFCU Final Regulation