March 31, 2014

CFPB releases small-entity guide on TILA-RESPA

April 1, 2014 – The CFPB on Monday released a Small Entity Compliance Guide for its integrated disclosure rule for the Truth in Lending and Real Estate Settlement Acts.

The CFPB has been publishing small entity compliance guides for each of its mortgage regulations. The guide for the TILA-RESPA rule emphasizes that creditors may not use the new integrated disclosures prior to the rule's effective date, August 1, 2015. Instead, creditors should follow the current disclosure requirements under Regulations X and Z, and use the existing forms for applications received before the effective date.

Other provisions addressed in Monday's update include:

  • which transactions the rule covers,
  • record retention requirements,
  • disclosure obligations for transactions not covered by the rule, and
  • Loan Estimate requirements under the rule.

NAFCU's compliance team put out a new chart on the scope and applicability of the TILA-RESPA integrated disclosure rule today, as well as the first of a series of articles on TILA-RESPA in theCompliance Monitor (login required).