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CFPB RESPA/TILA Rule Reference: 4.1-4.3, Page 18-19, CFPB Detailed Summary of the Rule
The complexity of the ruling starts in the first few pages with the new Closing Disclosure Form and Loan Estimate form, but let’s make sure we don’t get completely distracted by the new. For the types of transactions we discussed in previous posts, creditors don’t have to provide:
• The RESPA Settlement Cost booklet, settlement statement, and application serving disclosure requirements
• A Loan Estimate, closing disclosure, or special information booklet
Although the ruling states you could use the Loan Estimate and Closing Disclosure, it is very clear to state you CANNOT use these forms instead of the GFE, HUD, of Truth in Lending when they are required.
Now we know that there will be different categories of closings in the TILA-RESPA rule, and that there will be different forms required based on the category of closing. But will the basic education of these categories be enough for your employees to keep this straight on a regular basis when the new rule is effective on Aug. 1, 2015?
The truth is, it’s in everyone’s best interest to keep things straight with tools and technology. Sure that’s a given, but here’s what may not be so obvious: your technology provider should be working on these items now so you can be prepared to learn how to do it 6 months before August 2015.
While the business impact seems minimal, as it’s primarily around the control of which forms to use for what deal, what cannot be stressed enough is YOU DON’T HAVE AS MUCH TIME AS YOU THINK! Get started today and be prepared when that date arrives!
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.