The Consumer Financial Protection Bureau (CFPB) published a final rule to implement the new integrated disclosures on November 20, 2013. The rule completes the Dodd-Frank mandate to combine the disclosures required by the Truth-in-Lending (TILA) and Real Estate Settlement Procedure Acts (RESPA). The final rule was scheduled to be effective on August 1, 2015. The CFPB proposed to change the effective date to October 3, 2015 and that date is now finalized.
The new Loan Estimate form combines the old Good Faith Estimate with an early Truth in Lending Disclosure. The new Closing Disclosure combines the old HUD-1/A with the final Truth in Lending Disclosure. The forms are different, as are the rules surrounding the forms. Coverage, timing and many other requirements have changed.
The Understanding and Implementing the New TRID Rules training manual provides all of the information needed to understand the new regulations.
The manual covers:
The new, expanded coverage and exemption rules;
The effective date of the new rules and how it is applied;
The timing and content rules for the Loan Estimate, including extensive instructions for completing the form;
The timing and content rules for the Closing Disclosure, including extensive instructions for completing the form;
The limits on pre-disclosure activities;
When estimates are considered to be “in good faith” and the applicable tolerances;
When revised disclosures are allowed, including situations such as changed circumstances and borrower requests;
When revised disclosures are needed and how they are delivered;
Changes before consummation that do not require a new waiting period;
Changes before consummation that require a new waiting period;
Rules regarding changes due to events occurring after consummation;
When refunds are required and how to make the refund;
Rules related to the new Special Information Booklet;
Compliance Resource training manuals are designed to be used when conducting in-house training, whether initial training upon implementation of the new requirement, periodic training for new team members or remedial training for longer-term team members.