On the Horizon: Combined RESPA-TILA Disclosures

Financial Institutions

July 01, 2014
by John Moniak, CRCM

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John Moniak John Moniak, CRCM
Senior Manager - Regulatory Compliance

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On August 1, 2015, the CFPB’s much anticipated Truth in Lending Act/Real Estate Settlement Procedures Act (TILA-RESPA) combined disclosure rule takes effect. The revised disclosures will replace the multiple disclosures currently required individually by RESPA and Truth in Lending with a Loan Estimate Disclosure (Loan Estimate) and a Closing Disclosure. Many of the timing, tolerance, and redisclosure requirements remain unchanged.
This TILA-RESPA rule applies to most closed-end consumer credit transactions secured by real property, including credit extended to certain trusts for tax or estate planning purposes. Certain types of loans currently subject to TILA but not RESPA (construction-only loans and loans secured by vacant land or by 25 or more acres) will be subject to the TILA-RESPA rule’s integrated disclosure requirements. The rule will not apply to HELOCs, reverse mortgages, or chattel-dwelling loans, such as loans secured by a mobile home or by a dwelling that is not attached to real property.

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