Understanding the New Integrated Disclosure Rules
- 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.
Managers, compliance officers, loan officers, auditors and others responsible for preparing, delivering or auditing the new disclosures..
Jack Holzknecht, CRCM, has been delivering the word on lending compliance for 38 years. Jack’s career began as a federal bank examiner. He also headed the form and software division of a regional consulting company. He has developed and presented training programs to bankers in 43 states. He also developed and delivered training for the FDIC.
Institute of Certified Bankers: Visit http://www.icbmembers.org/login.aspx for instructions regarding self-reporting. Estimated credits: 2 CE Credits.
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