Integrated Disclosures: General Rules
The changes are massive. With the August 1 effective date barely a month away, we're re-broadcasting this popular series for those who still need help or would like confirmation of their efforts.
The CFPB published a final rule to implement the new integrated disclosures on November 20, 2013. The rule completes the Dodd-Frank mandate to combine the disclosures required by TILA and RESPA.
The new Loan Estimate form combines the old Good Faith Estimate with an early Truth in Lending disclosure. The new Closing Disclosure combines the old HUD-1/A with the final Truth in Lending Disclosure. The forms are different, as are the rules surrounding the forms. Coverage, timing and many other requirements have changed.
General Rules – 6/22/25 (broadcast 2/17/15)
- The new, expanded coverage and exemption rules including:
- Which departments and products are covered?
- The effective date of the new rule and how it is applied;
- The timing rules for the Loan Estimate and Closing Disclosure;
- The limits on pre-disclosure activities;
- When estimates are considered to be “in good faith” and the applicable tolerances;
- When revised disclosures are allowed, including situations such as changed circumstances and borrower requests;
- When revised disclosures are needed and how they are delivered;
- Changes before consummation that do not require a new waiting period;
- Changes before consummation that do require a new waiting period; and
- Rules regarding changes due to events occurring after consummation.
Loan origination software will play a key role in implementation, but there is much to complete before using the revised software. Restructuring product types and features may be necessary. You must decide which tasks are to be performed by the settlement agent and by your institution. Third-party settlement service providers need to be informed of the changes. Staff members need training. And, the loan origination software must be tested. This three-part program provides all of the information needed to understand the new forms and the new requirements.
Managers, compliance officers, loan officers, auditors and others responsible for preparing, delivering or auditing the new disclosures.
Jack Holzknecht, CRCM
The speaker will not be available to answer questions live during the re-broadcasts; however, registrants will have until midnight following these sessions to submit their questions via email.
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