The Consumer Financial Protection Bureau’s (CFPB) final integrated mortgage disclosure form rule is a massive 1,888-page regulation. It can be tricky to find specific answers to your questions. The CFPB released guidance on March 31 that provides a summary of the final rule. The guide is 89 pages and offers answers to technical compliance questions such as timing, delivery and revisions to the forms.
The document is designed to be a small entity compliance guide, meeting the requirements of the Small Business Regulatory Enforcement Fairness Act of 1996, which requires the bureau to issue guidance to help small entities comply with new regulations. However, the bureau indicated that the guide is also meant to provide an easy-to-use summary of the RESPA/Truth in Lending Act (TILA) rule in general. The guide explains that if an application from a consumer is received on or after Aug. 1, 2015, the new disclosure forms must be used. For an application received prior to that date, the current Good Faith Estimate (GFE) and HUD-1 Settlement Statement should be used.
In addition, the new disclosures cannot be used before the effective date.
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