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CFPB RESPA/TILA Rule Reference: 3.1-3.3, Page 16-7, CFPB Detailed Summary of the Rule
What are the new forms you will need under the TILA-RESPA rule? Will they replace any existing forms currently used? Today we quickly answer this question by summarizing the new forms of the TILA-RESPA rule:
- Replacing the Good Faith Estimate (GFE) and the Truth-in-Lending disclosure (TIL)
- Must be provided to the consumer no later than 3 days after they submit the loan application
- Replacing the HUD-1
- Must be provided to the consumer at least 3 days prior to consummation
The new forms go into effect August 1, 2015. Creditors will still be required to use the original forms (GFE, HUD-1 & Truth-in-Lending) on any applications received prior to August 1, 2015. The new forms cannot be used prior to the effective date.
This expresses the need for businesses to improve their technology and adapt their current processes to be able to make a distinction of what deals fall into what set of forms. August 1, 2015, might seem like a distant date, but businesses need to start making all of the changes now to stay ahead of the ruling and to be efficiently prepared. The question becomes, will your processes be adequate to distinguish between them both in technology and human execution?
For more information on the impact to the industry and how technology solutions can help your business mitigate them, visit the TilaRespa Knowledge Center.
All information and views expressed or implied are provided without warranty and are only the opinion of Pavaso, Inc. Each participant should seek legal representation for legal interpretation of the ruling and the CFPB directly for final instruction and interpretation. The final rule can be found here.