CFPB Released Final RESPA-TILA Integration Rule
As expected, the Bureau of Consumer Financial Protection (CFPB) released its final RESPA-TILA integration rule and associated forms on November 20th. The 1,900-page final rule establishes new forms including a "Loan Estimate," which would combine HUD's good faith estimate (GFE) and the early Truth-in-Lending (TIL) disclosures and a "Closing Disclosure" combining the HUD-1 and final TIL disclosures.
The final rule also makes several important rule changes including:
a mandatory three business day waiting period between the provision of the Closing Disclosure and closing, new zero tolerances for cost changes for services provided by a lender or its affiliates and several other new requirements governing the provision of the new forms.
Not included in the final rule at this time was the proposed "All-In" APR, which is an advocacy "win" for the mortgage industry.
The implementation date of the final rule is August 1, 2015 - which gives the industry nearly 20 months to prepare
Click here for CFPB Integrated Rule web page
Click here for final rule (1888 pages)
Click here for the MBA's preliminary summary of the final rule