What are the New Forms Effective October 3, 2015?
CB Title is committed to providing you with training and reference materials related to the new regulations and forms coming October 3rd. Please see below a refresher of our series of informational bulletins about the new CFPB forms.
On November 20, 2013, the CFPB announced the completion of their new integrated mortgage disclosure forms along with their regulations (RESPA Regulation X and TILA Regulation Z) for the proper completion and timely delivery to the consumer. These regulations are known as “the Rule”. In July 2015, the Consumer Financial Protection Agency issued a final rule setting the effective date at October 3, 2015.
Any residential loan originated on or after October 3, 2015 will be subject to the new rules and forms set forth by the CFPB. The Rule replaces the Good Faith Estimate (GFE) and early TILA form with the new Loan Estimate. It also replaces the HUD-1 Settlement Statement and final TILA form with the new Closing Disclosure. The introduction of the new disclosure forms require changes to the systems that produce the closing forms. Our company has prepared our production systems to provide the new required fee quotes, generate the new closing disclosure forms, and track the delivery and waiting periods required by the new regulations.
The Loan Estimate – Currently, borrowers receive two separate forms from their lender at the beginning of the transaction: the Good Faith Estimate (GFE), a form required under the RESPA, and the initial disclosure required under TILA. For loan applications taken on or after October 3, 2015 the creditor will instead use a combined Loan Estimate form. The new three-page Loan Estimate form must be provided to borrowers on a timetable similar to the current receipt of the GFE.
The Closing Disclosure – The combination of forms continues at the end of the transaction as well, with the HUD-1 Settlement Statement and the final TILA forms now combined into a single Closing Disclosure form. This new five-page form is used not only to disclose many terms and provisions of the loan, but also the financial transaction of the closing.
See our next bulletin in this series for more information. Feel free to contact us with any questions.
This bulletin is sent courtesy of CB Title Group, LLC and Fidelity National. This article is for informational purposes only and is not intended to provide legal advice, but rather to provide insight into legal developments and issues that may be useful to our clients and friends. In no circumstance is this article intended to be a full treatment of the above subject matter. Reader is advised to obtain additional information as noted.