CFPB STC Finalized Rule on Integrated Disclosures
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![Page 1: CFPB STC Finalized Rule on Integrated Disclosures](https://reader034.fdocuments.us/reader034/viewer/2022051818/54b5e3e44a7959e4058b456f/html5/thumbnails/1.jpg)
1
Understandingthe CFPB Final Rule on Integrated Disclosures
Presented by: Noah BlantonJanuary, 2014
![Page 2: CFPB STC Finalized Rule on Integrated Disclosures](https://reader034.fdocuments.us/reader034/viewer/2022051818/54b5e3e44a7959e4058b456f/html5/thumbnails/2.jpg)
- About the CFPB
- Effective Date
- Loan Estimate
- Closing Disclosure
- Delivery Alternatives
- Three-Day Rule
- All-In APR
- Electronic Storage
- Proposals Not
Adopted
Today’s Topics
History of Disclosures
About the CFPB
Mortgage Rules
- Service Providers
- QM / ATR
- Integrated Disclosures
Final Rule
Loan Estimate
- Refinance
Closing Disclosure
- Purchase – Buyer
- Purchase - Seller
Resources
Takeaways
What Lies Ahead?
Q & A
2© Copyright Stewart 2014
Disclaimer
The information in this presentation, event and/or printed material is provided for informational purposes only. None of the materials or opinions is offered, or should be construed, as legal advice. Communication of information by or through these means and your receipt or use of such information is not to be construed as legal advice or to constitute an attorney-client relationship.
You should not act or rely upon information contained in these materials without specifically seeking professional legal advice. Additional resources that may be referenced in the following presentation or materials are offered merely as a convenience to participants with no guarantees made as to the applicability or validity of the third-party content. We do not take any responsibility for the content, accuracy or timeliness of referenced websites, articles, books, events, etc.; nor do we endorse any commercial products that may be advertised or available on those sites.
Stewart endeavors to comply with all applicable legal and ethical requirements when providing information to industry participants.
![Page 3: CFPB STC Finalized Rule on Integrated Disclosures](https://reader034.fdocuments.us/reader034/viewer/2022051818/54b5e3e44a7959e4058b456f/html5/thumbnails/3.jpg)
- About the CFPB
- Effective Date
- Loan Estimate
- Closing Disclosure
- Delivery Alternatives
- Three-Day Rule
- All-In APR
- Electronic Storage
- Proposals Not
Adopted
Today’s Topics
History of Disclosures
About the CFPB
Mortgage Rules
- Service Providers
- QM / ATR
- Integrated Disclosures
Final Rule
Loan Estimate
- Refinance
Closing Disclosure
- Purchase – Buyer
- Purchase - Seller
Resources
Takeaways
What Lies Ahead?
Q & A
3© Copyright Stewart 2014
History of Disclosures – Truth-in-Lending
� Truth-in-Lending Act (TILA) of 1968
� Implemented by Federal Reserve Board
� Promulgated Regulation Z
� Created Truth-in-Lending Statement
� Discloses the following:
� Cost of credit
� Repayment terms of mortgage
� Annual percentage rate (APR)
� Loan rate
� Fees amortized over expected life of loan
� Discloses finance charges, amount financed, total
number of payments, whether interest can change,
whether loan can be refinanced
![Page 4: CFPB STC Finalized Rule on Integrated Disclosures](https://reader034.fdocuments.us/reader034/viewer/2022051818/54b5e3e44a7959e4058b456f/html5/thumbnails/4.jpg)
- About the CFPB
- Effective Date
- Loan Estimate
- Closing Disclosure
- Delivery Alternatives
- Three-Day Rule
- All-In APR
- Electronic Storage
- Proposals Not
Adopted
Today’s Topics
History of Disclosures
About the CFPB
Mortgage Rules
- Service Providers
- QM / ATR
- Integrated Disclosures
Final Rule
Loan Estimate
- Refinance
Closing Disclosure
- Purchase – Buyer
- Purchase - Seller
Resources
Takeaways
What Lies Ahead?
Q & A
4© Copyright Stewart 2014
History of Disclosures - RESPA
� Real Estate Settlement Procedures Act of 1974
� RESPA was implemented by HUD
� Promulgated Regulation X
� Created Good Faith Estimate
� Standardized disclosures of closing costs
� Included costs associated with mortgages
� HUD-1 and GFE modified in 2010
![Page 5: CFPB STC Finalized Rule on Integrated Disclosures](https://reader034.fdocuments.us/reader034/viewer/2022051818/54b5e3e44a7959e4058b456f/html5/thumbnails/5.jpg)
- About the CFPB
- Effective Date
- Loan Estimate
- Closing Disclosure
- Delivery Alternatives
- Three-Day Rule
- All-In APR
- Electronic Storage
- Proposals Not
Adopted
Today’s Topics
History of Disclosures
About the CFPB
Mortgage Rules
- Service Providers
- QM / ATR
- Integrated Disclosures
Final Rule
Loan Estimate
- Refinance
Closing Disclosure
- Purchase – Buyer
- Purchase - Seller
Resources
Takeaways
What Lies Ahead?
Q & A
5© Copyright Stewart 2014
The market peaked in 2007….
The CFPB Timeline
2007 2008 2009 2010 2011 2012 2013
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- About the CFPB
- Effective Date
- Loan Estimate
- Closing Disclosure
- Delivery Alternatives
- Three-Day Rule
- All-In APR
- Electronic Storage
- Proposals Not
Adopted
Today’s Topics
History of Disclosures
About the CFPB
Mortgage Rules
- Service Providers
- QM / ATR
- Integrated Disclosures
Final Rule
Loan Estimate
- Refinance
Closing Disclosure
- Purchase – Buyer
- Purchase - Seller
Resources
Takeaways
What Lies Ahead?
Q & A
6© Copyright Stewart 2014
Officially dubbed “Financial Collapse” in 2008
The CFPB Timeline
2007 2008 2009 2010 2011 2012 2013
![Page 7: CFPB STC Finalized Rule on Integrated Disclosures](https://reader034.fdocuments.us/reader034/viewer/2022051818/54b5e3e44a7959e4058b456f/html5/thumbnails/7.jpg)
- About the CFPB
- Effective Date
- Loan Estimate
- Closing Disclosure
- Delivery Alternatives
- Three-Day Rule
- All-In APR
- Electronic Storage
- Proposals Not
Adopted
Today’s Topics
History of Disclosures
About the CFPB
Mortgage Rules
- Service Providers
- QM / ATR
- Integrated Disclosures
Final Rule
Loan Estimate
- Refinance
Closing Disclosure
- Purchase – Buyer
- Purchase - Seller
Resources
Takeaways
What Lies Ahead?
Q & A
7© Copyright Stewart 2014
The CFPB Timeline
The push for financial regulatory reform began in 2009
2007 2008 2009 2010 2011 2012 2013
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- About the CFPB
- Effective Date
- Loan Estimate
- Closing Disclosure
- Delivery Alternatives
- Three-Day Rule
- All-In APR
- Electronic Storage
- Proposals Not
Adopted
Today’s Topics
History of Disclosures
About the CFPB
Mortgage Rules
- Service Providers
- QM / ATR
- Integrated Disclosures
Final Rule
Loan Estimate
- Refinance
Closing Disclosure
- Purchase – Buyer
- Purchase - Seller
Resources
Takeaways
What Lies Ahead?
Q & A
8© Copyright Stewart 2014
The CFPB Timeline
2007 2008 2009 2010 2011 2012 2013
![Page 9: CFPB STC Finalized Rule on Integrated Disclosures](https://reader034.fdocuments.us/reader034/viewer/2022051818/54b5e3e44a7959e4058b456f/html5/thumbnails/9.jpg)
- About the CFPB
- Effective Date
- Loan Estimate
- Closing Disclosure
- Delivery Alternatives
- Three-Day Rule
- All-In APR
- Electronic Storage
- Proposals Not
Adopted
Today’s Topics
History of Disclosures
About the CFPB
Mortgage Rules
- Service Providers
- QM / ATR
- Integrated Disclosures
Final Rule
Loan Estimate
- Refinance
Closing Disclosure
- Purchase – Buyer
- Purchase - Seller
Resources
Takeaways
What Lies Ahead?
Q & A
9© Copyright Stewart 2014
About the CFPB
� CFPB formed with Richard Cordray as Director
� Supervisory authority over Banks and Non-Banks.
� Enforcement authority over RESPA and TILA
-
2007 2008 2009 2010 2011 2012 2013
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- About the CFPB
- Effective Date
- Loan Estimate
- Closing Disclosure
- Delivery Alternatives
- Three-Day Rule
- All-In APR
- Electronic Storage
- Proposals Not
Adopted
Today’s Topics
History of Disclosures
About the CFPB
Mortgage Rules
- Service Providers
- QM / ATR
- Integrated Disclosures
Final Rule
Loan Estimate
- Refinance
Closing Disclosure
- Purchase – Buyer
- Purchase - Seller
Resources
Takeaways
What Lies Ahead?
Q & A
10© Copyright Stewart 2014
The CFPB Timeline
Proposed and finalized many rules in 2012
2007 2008 2009 2010 2011 2012 2013
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- About the CFPB
- Effective Date
- Loan Estimate
- Closing Disclosure
- Delivery Alternatives
- Three-Day Rule
- All-In APR
- Electronic Storage
- Proposals Not
Adopted
Today’s Topics
History of Disclosures
About the CFPB
Mortgage Rules
- Service Providers
- QM / ATR
- Integrated Disclosures
Final Rule
Loan Estimate
- Refinance
Closing Disclosure
- Purchase – Buyer
- Purchase - Seller
Resources
Takeaways
What Lies Ahead?
Q & A
11© Copyright Stewart 2014
The CFPB Timeline
Released the Final Rule on Integrated Disclosures -November 20, 2013 at the CFPB Field Hearing in Boston as part of the “Know Before You Owe” initiative.
Stewart’s policy analyst talks with CFPB Director, Richard
Cordray about Stewart’s effort to provide education on the new
disclosures.
2007 2008 2009 2010 2011 2012 2013
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- About the CFPB
- Effective Date
- Loan Estimate
- Closing Disclosure
- Delivery Alternatives
- Three-Day Rule
- All-In APR
- Electronic Storage
- Proposals Not
Adopted
Today’s Topics
History of Disclosures
About the CFPB
Mortgage Rules
- Service Providers
- QM / ATR
- Integrated Disclosures
Final Rule
Loan Estimate
- Refinance
Closing Disclosure
- Purchase – Buyer
- Purchase - Seller
Resources
Takeaways
What Lies Ahead?
Q & A
12© Copyright Stewart 2014
CFPB Continues to Remedy Historic Closing Problems
Have you ever experienced one or more of the following?
� Buyer and real estate professional have arrived at the title company
for closing
� Buyer has no idea how much money they are responsible to bring
� Real estate professional is frustrated they have yet to receive a copy
of the HUD-1
� Loan officer is saying the title company is responsible for the delay
� Title company is saying they just received the loan package
When the consumer wins… we all win!
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- About the CFPB
- Effective Date
- Loan Estimate
- Closing Disclosure
- Delivery Alternatives
- Three-Day Rule
- All-In APR
- Electronic Storage
- Proposals Not
Adopted
Today’s Topics
History of Disclosures
About the CFPB
Mortgage Rules
- Service Providers
- QM / ATR
- Integrated Disclosures
Final Rule
Loan Estimate
- Refinance
Closing Disclosure
- Purchase – Buyer
- Purchase - Seller
Resources
Takeaways
What Lies Ahead?
Q & A
13© Copyright Stewart 2014
Preview of things to come in 2014
“So as part of our “Know Before You Owe” initiative, we are making a commitment to work with industry to improve the mortgage closing experience for consumers through technology. We believe that “eClosings” could represent a positive development along these lines, and we want to know more about how we can foster innovation in this area.
CFPB Director Richard CordrayBoston Field Hearing,November 20, 2013
![Page 14: CFPB STC Finalized Rule on Integrated Disclosures](https://reader034.fdocuments.us/reader034/viewer/2022051818/54b5e3e44a7959e4058b456f/html5/thumbnails/14.jpg)
- About the CFPB
- Effective Date
- Loan Estimate
- Closing Disclosure
- Delivery Alternatives
- Three-Day Rule
- All-In APR
- Electronic Storage
- Proposals Not
Adopted
Today’s Topics
History of Disclosures
About the CFPB
Mortgage Rules
- Service Providers
- QM / ATR
- Integrated Disclosures
Final Rule
Loan Estimate
- Refinance
Closing Disclosure
- Purchase – Buyer
- Purchase - Seller
Resources
Takeaways
What Lies Ahead?
Q & A
14© Copyright Stewart 2014
Mortgage Rules
Service Providers
Qualified Mortgages
Integrated Disclosures
![Page 15: CFPB STC Finalized Rule on Integrated Disclosures](https://reader034.fdocuments.us/reader034/viewer/2022051818/54b5e3e44a7959e4058b456f/html5/thumbnails/15.jpg)
- About the CFPB
- Effective Date
- Loan Estimate
- Closing Disclosure
- Delivery Alternatives
- Three-Day Rule
- All-In APR
- Electronic Storage
- Proposals Not
Adopted
Today’s Topics
History of Disclosures
About the CFPB
Mortgage Rules
- Service Providers
- QM / ATR
- Integrated Disclosures
Final Rule
Loan Estimate
- Refinance
Closing Disclosure
- Purchase – Buyer
- Purchase - Seller
Resources
Takeaways
What Lies Ahead?
Q & A
15© Copyright Stewart 2014
Service Provider “flight to quality”
CFPB Bulletin to Banks and Non-Banks stating they must use quality service providers.
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- About the CFPB
- Effective Date
- Loan Estimate
- Closing Disclosure
- Delivery Alternatives
- Three-Day Rule
- All-In APR
- Electronic Storage
- Proposals Not
Adopted
Today’s Topics
History of Disclosures
About the CFPB
Mortgage Rules
- Service Providers
- QM / ATR
- Integrated Disclosures
Final Rule
Loan Estimate
- Refinance
Closing Disclosure
- Purchase – Buyer
- Purchase - Seller
Resources
Takeaways
What Lies Ahead?
Q & A
16© Copyright Stewart 2014
Qualified Mortgage / Ability-to-Repay
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- About the CFPB
- Effective Date
- Loan Estimate
- Closing Disclosure
- Delivery Alternatives
- Three-Day Rule
- All-In APR
- Electronic Storage
- Proposals Not
Adopted
Today’s Topics
History of Disclosures
About the CFPB
Mortgage Rules
- Service Providers
- QM / ATR
- Integrated Disclosures
Final Rule
Loan Estimate
- Refinance
Closing Disclosure
- Purchase – Buyer
- Purchase - Seller
Resources
Takeaways
What Lies Ahead?
Q & A
17© Copyright Stewart 2014
CFPB Finalizes Rule on Integrated Disclosures
Better Disclosures
![Page 18: CFPB STC Finalized Rule on Integrated Disclosures](https://reader034.fdocuments.us/reader034/viewer/2022051818/54b5e3e44a7959e4058b456f/html5/thumbnails/18.jpg)
- About the CFPB
- Effective Date
- Loan Estimate
- Closing Disclosure
- Delivery Alternatives
- Three-Day Rule
- All-In APR
- Electronic Storage
- Proposals Not
Adopted
Today’s Topics
History of Disclosures
About the CFPB
Mortgage Rules
- Service Providers
- QM / ATR
- Integrated Disclosures
Final Rule
Loan Estimate
- Refinance
Closing Disclosure
- Purchase – Buyer
- Purchase - Seller
Resources
Takeaways
What Lies Ahead?
Q & A
18© Copyright Stewart 2014
Detailed Summary of the Final Rule
Detailed Summary – 7 pages
� Scope
� Loan Estimate
� Closing Disclosure
� Limits on Cost Increases
� Proposals Not Adopted
� Effective Date
*Final Rule – 1,888 pages
![Page 19: CFPB STC Finalized Rule on Integrated Disclosures](https://reader034.fdocuments.us/reader034/viewer/2022051818/54b5e3e44a7959e4058b456f/html5/thumbnails/19.jpg)
- About the CFPB
- Effective Date
- Loan Estimate
- Closing Disclosure
- Delivery Alternatives
- Three-Day Rule
- All-In APR
- Electronic Storage
- Proposals Not
Adopted
Today’s Topics
History of Disclosures
About the CFPB
Mortgage Rules
- Service Providers
- QM / ATR
- Integrated Disclosures
Final Rule
Loan Estimate
- Refinance
Closing Disclosure
- Purchase – Buyer
- Purchase - Seller
Resources
Takeaways
What Lies Ahead?
Q & A
19© Copyright Stewart 2014
Detailed Summary of the Final Rule
1 Scope
a) Applications on or after 8/1/2015 fall under new rules
b) Closed-end loans only - No home equity lines
c) No reverse mortgages
d) No mobile home loans
2 Loan Estimate
a) Replaces Good Faith Est. / Early Truth-in-Lending
b) Mortgage Broker may provide / Lender is still responsible
c) Delivery must be within 3 Business Days of ‘application’
d) Limitation on up-front fees with exception for credit reports
e) Disclaimer on early estimates used before Loan Estimate
3 Closing Disclosure
a) Replaces HUD-1 and Final Truth-in-Lending
b) Consumer must receive at least 3 business days before signing
c) APR changes over 1/8% require re-disclosure/ 3 Bus. Day wait
d) Escrow may prepare and/or deliver*
4 Limits on Increases
a) Items that generally cannot increase:
a) Creditor’s or broker’s charges for its own services
b) Charges for services provided by an affiliate
c) Charges where consumer is not permitted to shop
b) Other services can generally increase by 10% or less
4a Exceptions
a) Consumer requests the change
b) Consumer chooses their own service provider
c) Information at application is/becomes inaccurate
d) Loan Estimate expires
5 Not Adopteda) Re-defined “All In” APR
b) Storage in standard, electronic machine-readable format
c) Disclosure of Approximate Cost of Funds
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- About the CFPB
- Effective Date
- Loan Estimate
- Closing Disclosure
- Delivery Alternatives
- Three-Day Rule
- All-In APR
- Electronic Storage
- Proposals Not
Adopted
Today’s Topics
History of Disclosures
About the CFPB
Mortgage Rules
- Service Providers
- QM / ATR
- Integrated Disclosures
Final Rule
Loan Estimate
- Refinance
Closing Disclosure
- Purchase – Buyer
- Purchase - Seller
Resources
Takeaways
What Lies Ahead?
Q & A
20© Copyright Stewart 2014
� Help consumers by making all forms look similar
� Help consumers shop for best loan
� Help consumers guard against hikes in charges at closing
� Help consumers understand future obligations
CFPB Goals in Redesigning Forms
HUD-1Good Faith Estimate Truth in Lending
![Page 21: CFPB STC Finalized Rule on Integrated Disclosures](https://reader034.fdocuments.us/reader034/viewer/2022051818/54b5e3e44a7959e4058b456f/html5/thumbnails/21.jpg)
- About the CFPB
- Effective Date
- Loan Estimate
- Closing Disclosure
- Delivery Alternatives
- Three-Day Rule
- All-In APR
- Electronic Storage
- Proposals Not
Adopted
Today’s Topics
History of Disclosures
About the CFPB
Mortgage Rules
- Service Providers
- QM / ATR
- Integrated Disclosures
Final Rule
Loan Estimate
- Refinance
Closing Disclosure
- Purchase – Buyer
- Purchase - Seller
Resources
Takeaways
What Lies Ahead?
Q & A
21© Copyright Stewart 2014
Introducing the Forms
Today’s look at the samples provided by the Bureau in the final rule announced November 20, 2013.
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- About the CFPB
- Effective Date
- Loan Estimate
- Closing Disclosure
- Delivery Alternatives
- Three-Day Rule
- All-In APR
- Electronic Storage
- Proposals Not
Adopted
Today’s Topics
History of Disclosures
About the CFPB
Mortgage Rules
- Service Providers
- QM / ATR
- Integrated Disclosures
Final Rule
Loan Estimate
- Refinance
Closing Disclosure
- Purchase – Buyer
- Purchase - Seller
Resources
Takeaways
What Lies Ahead?
Q & A
22© Copyright Stewart 2014
How important are the new disclosures??
![Page 23: CFPB STC Finalized Rule on Integrated Disclosures](https://reader034.fdocuments.us/reader034/viewer/2022051818/54b5e3e44a7959e4058b456f/html5/thumbnails/23.jpg)
- About the CFPB
- Effective Date
- Loan Estimate
- Closing Disclosure
- Delivery Alternatives
- Three-Day Rule
- All-In APR
- Electronic Storage
- Proposals Not
Adopted
Today’s Topics
History of Disclosures
About the CFPB
Mortgage Rules
- Service Providers
- QM / ATR
- Integrated Disclosures
Final Rule
Loan Estimate
- Refinance
Closing Disclosure
- Purchase – Buyer
- Purchase - Seller
Resources
Takeaways
What Lies Ahead?
Q & A
23© Copyright Stewart 2014
Closing Disclosure for Purchase – Page 1
� Closing Information
� Transaction Information
� Loan Information
� Loan Terms
� Projected Payments
� Costs at Closing
![Page 24: CFPB STC Finalized Rule on Integrated Disclosures](https://reader034.fdocuments.us/reader034/viewer/2022051818/54b5e3e44a7959e4058b456f/html5/thumbnails/24.jpg)
- About the CFPB
- Effective Date
- Loan Estimate
- Closing Disclosure
- Delivery Alternatives
- Three-Day Rule
- All-In APR
- Electronic Storage
- Proposals Not
Adopted
Today’s Topics
History of Disclosures
About the CFPB
Mortgage Rules
- Service Providers
- QM / ATR
- Integrated Disclosures
Final Rule
Loan Estimate
- Refinance
Closing Disclosure
- Purchase – Buyer
- Purchase - Seller
Resources
Takeaways
What Lies Ahead?
Q & A
24© Copyright Stewart 2014
Closing Disclosure for Purchase – Page 1 - Detail
![Page 25: CFPB STC Finalized Rule on Integrated Disclosures](https://reader034.fdocuments.us/reader034/viewer/2022051818/54b5e3e44a7959e4058b456f/html5/thumbnails/25.jpg)
- About the CFPB
- Effective Date
- Loan Estimate
- Closing Disclosure
- Delivery Alternatives
- Three-Day Rule
- All-In APR
- Electronic Storage
- Proposals Not
Adopted
Today’s Topics
History of Disclosures
About the CFPB
Mortgage Rules
- Service Providers
- QM / ATR
- Integrated Disclosures
Final Rule
Loan Estimate
- Refinance
Closing Disclosure
- Purchase – Buyer
- Purchase - Seller
Resources
Takeaways
What Lies Ahead?
Q & A
25© Copyright Stewart 2014
Closing Disclosure for Purchase – Page 1 - Detail
![Page 26: CFPB STC Finalized Rule on Integrated Disclosures](https://reader034.fdocuments.us/reader034/viewer/2022051818/54b5e3e44a7959e4058b456f/html5/thumbnails/26.jpg)
- About the CFPB
- Effective Date
- Loan Estimate
- Closing Disclosure
- Delivery Alternatives
- Three-Day Rule
- All-In APR
- Electronic Storage
- Proposals Not
Adopted
Today’s Topics
History of Disclosures
About the CFPB
Mortgage Rules
- Service Providers
- QM / ATR
- Integrated Disclosures
Final Rule
Loan Estimate
- Refinance
Closing Disclosure
- Purchase – Buyer
- Purchase - Seller
Resources
Takeaways
What Lies Ahead?
Q & A
26© Copyright Stewart 2014
Closing Disclosure for Purchase – Page 2
� Loan Costs
� Other Costs
� Total Costs
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- About the CFPB
- Effective Date
- Loan Estimate
- Closing Disclosure
- Delivery Alternatives
- Three-Day Rule
- All-In APR
- Electronic Storage
- Proposals Not
Adopted
Today’s Topics
History of Disclosures
About the CFPB
Mortgage Rules
- Service Providers
- QM / ATR
- Integrated Disclosures
Final Rule
Loan Estimate
- Refinance
Closing Disclosure
- Purchase – Buyer
- Purchase - Seller
Resources
Takeaways
What Lies Ahead?
Q & A
27© Copyright Stewart 2014
Closing Disclosure for Purchase – Page 2 - Detail
![Page 28: CFPB STC Finalized Rule on Integrated Disclosures](https://reader034.fdocuments.us/reader034/viewer/2022051818/54b5e3e44a7959e4058b456f/html5/thumbnails/28.jpg)
- About the CFPB
- Effective Date
- Loan Estimate
- Closing Disclosure
- Delivery Alternatives
- Three-Day Rule
- All-In APR
- Electronic Storage
- Proposals Not
Adopted
Today’s Topics
History of Disclosures
About the CFPB
Mortgage Rules
- Service Providers
- QM / ATR
- Integrated Disclosures
Final Rule
Loan Estimate
- Refinance
Closing Disclosure
- Purchase – Buyer
- Purchase - Seller
Resources
Takeaways
What Lies Ahead?
Q & A
28© Copyright Stewart 2014
Closing Disclosure for Purchase – Page 2 - Detail
![Page 29: CFPB STC Finalized Rule on Integrated Disclosures](https://reader034.fdocuments.us/reader034/viewer/2022051818/54b5e3e44a7959e4058b456f/html5/thumbnails/29.jpg)
- About the CFPB
- Effective Date
- Loan Estimate
- Closing Disclosure
- Delivery Alternatives
- Three-Day Rule
- All-In APR
- Electronic Storage
- Proposals Not
Adopted
Today’s Topics
History of Disclosures
About the CFPB
Mortgage Rules
- Service Providers
- QM / ATR
- Integrated Disclosures
Final Rule
Loan Estimate
- Refinance
Closing Disclosure
- Purchase – Buyer
- Purchase - Seller
Resources
Takeaways
What Lies Ahead?
Q & A
29© Copyright Stewart 2014
Closing Disclosure for Purchase – Page 3
� Cash-to-Close Calculations
� Transaction Summaries
![Page 30: CFPB STC Finalized Rule on Integrated Disclosures](https://reader034.fdocuments.us/reader034/viewer/2022051818/54b5e3e44a7959e4058b456f/html5/thumbnails/30.jpg)
- About the CFPB
- Effective Date
- Loan Estimate
- Closing Disclosure
- Delivery Alternatives
- Three-Day Rule
- All-In APR
- Electronic Storage
- Proposals Not
Adopted
Today’s Topics
History of Disclosures
About the CFPB
Mortgage Rules
- Service Providers
- QM / ATR
- Integrated Disclosures
Final Rule
Loan Estimate
- Refinance
Closing Disclosure
- Purchase – Buyer
- Purchase - Seller
Resources
Takeaways
What Lies Ahead?
Q & A
30© Copyright Stewart 2014
Closing Disclosure for Purchase – Page 3 - Detail
![Page 31: CFPB STC Finalized Rule on Integrated Disclosures](https://reader034.fdocuments.us/reader034/viewer/2022051818/54b5e3e44a7959e4058b456f/html5/thumbnails/31.jpg)
- About the CFPB
- Effective Date
- Loan Estimate
- Closing Disclosure
- Delivery Alternatives
- Three-Day Rule
- All-In APR
- Electronic Storage
- Proposals Not
Adopted
Today’s Topics
History of Disclosures
About the CFPB
Mortgage Rules
- Service Providers
- QM / ATR
- Integrated Disclosures
Final Rule
Loan Estimate
- Refinance
Closing Disclosure
- Purchase – Buyer
- Purchase - Seller
Resources
Takeaways
What Lies Ahead?
Q & A
31© Copyright Stewart 2014
Closing Disclosure for Purchase – Page 3 - Detail
![Page 32: CFPB STC Finalized Rule on Integrated Disclosures](https://reader034.fdocuments.us/reader034/viewer/2022051818/54b5e3e44a7959e4058b456f/html5/thumbnails/32.jpg)
- About the CFPB
- Effective Date
- Loan Estimate
- Closing Disclosure
- Delivery Alternatives
- Three-Day Rule
- All-In APR
- Electronic Storage
- Proposals Not
Adopted
Today’s Topics
History of Disclosures
About the CFPB
Mortgage Rules
- Service Providers
- QM / ATR
- Integrated Disclosures
Final Rule
Loan Estimate
- Refinance
Closing Disclosure
- Purchase – Buyer
- Purchase - Seller
Resources
Takeaways
What Lies Ahead?
Q & A
32© Copyright Stewart 2014
Closing Disclosure for Purchase – Page 4
� Loan Disclosures
� Escrow Account
![Page 33: CFPB STC Finalized Rule on Integrated Disclosures](https://reader034.fdocuments.us/reader034/viewer/2022051818/54b5e3e44a7959e4058b456f/html5/thumbnails/33.jpg)
- About the CFPB
- Effective Date
- Loan Estimate
- Closing Disclosure
- Delivery Alternatives
- Three-Day Rule
- All-In APR
- Electronic Storage
- Proposals Not
Adopted
Today’s Topics
History of Disclosures
About the CFPB
Mortgage Rules
- Service Providers
- QM / ATR
- Integrated Disclosures
Final Rule
Loan Estimate
- Refinance
Closing Disclosure
- Purchase – Buyer
- Purchase - Seller
Resources
Takeaways
What Lies Ahead?
Q & A
33© Copyright Stewart 2014
Closing Disclosure for Purchase – Page 4 - Detail
![Page 34: CFPB STC Finalized Rule on Integrated Disclosures](https://reader034.fdocuments.us/reader034/viewer/2022051818/54b5e3e44a7959e4058b456f/html5/thumbnails/34.jpg)
- About the CFPB
- Effective Date
- Loan Estimate
- Closing Disclosure
- Delivery Alternatives
- Three-Day Rule
- All-In APR
- Electronic Storage
- Proposals Not
Adopted
Today’s Topics
History of Disclosures
About the CFPB
Mortgage Rules
- Service Providers
- QM / ATR
- Integrated Disclosures
Final Rule
Loan Estimate
- Refinance
Closing Disclosure
- Purchase – Buyer
- Purchase - Seller
Resources
Takeaways
What Lies Ahead?
Q & A
34© Copyright Stewart 2014
Closing Disclosure for Purchase – Page 5
� Loan Calculations
� Other Disclosures
� Questions
� Contact Information
� Confirmation of Receipt
![Page 35: CFPB STC Finalized Rule on Integrated Disclosures](https://reader034.fdocuments.us/reader034/viewer/2022051818/54b5e3e44a7959e4058b456f/html5/thumbnails/35.jpg)
- About the CFPB
- Effective Date
- Loan Estimate
- Closing Disclosure
- Delivery Alternatives
- Three-Day Rule
- All-In APR
- Electronic Storage
- Proposals Not
Adopted
Today’s Topics
History of Disclosures
About the CFPB
Mortgage Rules
- Service Providers
- QM / ATR
- Integrated Disclosures
Final Rule
Loan Estimate
- Refinance
Closing Disclosure
- Purchase – Buyer
- Purchase - Seller
Resources
Takeaways
What Lies Ahead?
Q & A
35© Copyright Stewart 2014
Closing Disclosure for Purchase – Page 5
![Page 36: CFPB STC Finalized Rule on Integrated Disclosures](https://reader034.fdocuments.us/reader034/viewer/2022051818/54b5e3e44a7959e4058b456f/html5/thumbnails/36.jpg)
- About the CFPB
- Effective Date
- Loan Estimate
- Closing Disclosure
- Delivery Alternatives
- Three-Day Rule
- All-In APR
- Electronic Storage
- Proposals Not
Adopted
Today’s Topics
History of Disclosures
About the CFPB
Mortgage Rules
- Service Providers
- QM / ATR
- Integrated Disclosures
Final Rule
Loan Estimate
- Refinance
Closing Disclosure
- Purchase – Buyer
- Purchase - Seller
Resources
Takeaways
What Lies Ahead?
Q & A
36© Copyright Stewart 2014
Closing Disclosure for Purchase – Page 5
![Page 37: CFPB STC Finalized Rule on Integrated Disclosures](https://reader034.fdocuments.us/reader034/viewer/2022051818/54b5e3e44a7959e4058b456f/html5/thumbnails/37.jpg)
- About the CFPB
- Effective Date
- Loan Estimate
- Closing Disclosure
- Delivery Alternatives
- Three-Day Rule
- All-In APR
- Electronic Storage
- Proposals Not
Adopted
Today’s Topics
History of Disclosures
About the CFPB
Mortgage Rules
- Service Providers
- QM / ATR
- Integrated Disclosures
Final Rule
Loan Estimate
- Refinance
Closing Disclosure
- Purchase – Buyer
- Purchase - Seller
Resources
Takeaways
What Lies Ahead?
Q & A
37© Copyright Stewart 2014
Closing Disclosure for Seller Only – Page 1
� Closing Information
� Transaction Information
� Summaries of Transactions
� Contact Information
![Page 38: CFPB STC Finalized Rule on Integrated Disclosures](https://reader034.fdocuments.us/reader034/viewer/2022051818/54b5e3e44a7959e4058b456f/html5/thumbnails/38.jpg)
- About the CFPB
- Effective Date
- Loan Estimate
- Closing Disclosure
- Delivery Alternatives
- Three-Day Rule
- All-In APR
- Electronic Storage
- Proposals Not
Adopted
Today’s Topics
History of Disclosures
About the CFPB
Mortgage Rules
- Service Providers
- QM / ATR
- Integrated Disclosures
Final Rule
Loan Estimate
- Refinance
Closing Disclosure
- Purchase – Buyer
- Purchase - Seller
Resources
Takeaways
What Lies Ahead?
Q & A
38© Copyright Stewart 2014
Closing Disclosure for Seller Only – Page 1 - Detail
![Page 39: CFPB STC Finalized Rule on Integrated Disclosures](https://reader034.fdocuments.us/reader034/viewer/2022051818/54b5e3e44a7959e4058b456f/html5/thumbnails/39.jpg)
- About the CFPB
- Effective Date
- Loan Estimate
- Closing Disclosure
- Delivery Alternatives
- Three-Day Rule
- All-In APR
- Electronic Storage
- Proposals Not
Adopted
Today’s Topics
History of Disclosures
About the CFPB
Mortgage Rules
- Service Providers
- QM / ATR
- Integrated Disclosures
Final Rule
Loan Estimate
- Refinance
Closing Disclosure
- Purchase – Buyer
- Purchase - Seller
Resources
Takeaways
What Lies Ahead?
Q & A
39© Copyright Stewart 2014
Closing Disclosure for Seller Only – Page 1 - Detail
![Page 40: CFPB STC Finalized Rule on Integrated Disclosures](https://reader034.fdocuments.us/reader034/viewer/2022051818/54b5e3e44a7959e4058b456f/html5/thumbnails/40.jpg)
- About the CFPB
- Effective Date
- Loan Estimate
- Closing Disclosure
- Delivery Alternatives
- Three-Day Rule
- All-In APR
- Electronic Storage
- Proposals Not
Adopted
Today’s Topics
History of Disclosures
About the CFPB
Mortgage Rules
- Service Providers
- QM / ATR
- Integrated Disclosures
Final Rule
Loan Estimate
- Refinance
Closing Disclosure
- Purchase – Buyer
- Purchase - Seller
Resources
Takeaways
What Lies Ahead?
Q & A
40© Copyright Stewart 2014
Closing Disclosure for Seller Only – Page 2
� Closing Cost Details
� Loan Costs
� Other Costs
![Page 41: CFPB STC Finalized Rule on Integrated Disclosures](https://reader034.fdocuments.us/reader034/viewer/2022051818/54b5e3e44a7959e4058b456f/html5/thumbnails/41.jpg)
- About the CFPB
- Effective Date
- Loan Estimate
- Closing Disclosure
- Delivery Alternatives
- Three-Day Rule
- All-In APR
- Electronic Storage
- Proposals Not
Adopted
Today’s Topics
History of Disclosures
About the CFPB
Mortgage Rules
- Service Providers
- QM / ATR
- Integrated Disclosures
Final Rule
Loan Estimate
- Refinance
Closing Disclosure
- Purchase – Buyer
- Purchase - Seller
Resources
Takeaways
What Lies Ahead?
Q & A
41© Copyright Stewart 2014
Closing Disclosure for Seller Only – Page 2 - Detail
![Page 42: CFPB STC Finalized Rule on Integrated Disclosures](https://reader034.fdocuments.us/reader034/viewer/2022051818/54b5e3e44a7959e4058b456f/html5/thumbnails/42.jpg)
- About the CFPB
- Effective Date
- Loan Estimate
- Closing Disclosure
- Delivery Alternatives
- Three-Day Rule
- All-In APR
- Electronic Storage
- Proposals Not
Adopted
Today’s Topics
History of Disclosures
About the CFPB
Mortgage Rules
- Service Providers
- QM / ATR
- Integrated Disclosures
Final Rule
Loan Estimate
- Refinance
Closing Disclosure
- Purchase – Buyer
- Purchase - Seller
Resources
Takeaways
What Lies Ahead?
Q & A
42© Copyright Stewart 2014
Closing Disclosure for Seller Only – Page 2 - Detail
![Page 43: CFPB STC Finalized Rule on Integrated Disclosures](https://reader034.fdocuments.us/reader034/viewer/2022051818/54b5e3e44a7959e4058b456f/html5/thumbnails/43.jpg)
- About the CFPB
- Effective Date
- Loan Estimate
- Closing Disclosure
- Delivery Alternatives
- Three-Day Rule
- All-In APR
- Electronic Storage
- Proposals Not
Adopted
Today’s Topics
History of Disclosures
About the CFPB
Mortgage Rules
- Service Providers
- QM / ATR
- Integrated Disclosures
Final Rule
Loan Estimate
- Refinance
Closing Disclosure
- Purchase – Buyer
- Purchase - Seller
Resources
Takeaways
What Lies Ahead?
Q & A
43© Copyright Stewart 2014
Resources
stewart.com/cfpb
� Service Provider Memo
� ALTA Best Practices
� QM / ATR
� Integrated Disclosures� Loan Estimate
� Closing Disclosure
� Realtor info
� Lender info
� Homebuyer education
![Page 44: CFPB STC Finalized Rule on Integrated Disclosures](https://reader034.fdocuments.us/reader034/viewer/2022051818/54b5e3e44a7959e4058b456f/html5/thumbnails/44.jpg)
- About the CFPB
- Effective Date
- Loan Estimate
- Closing Disclosure
- Delivery Alternatives
- Three-Day Rule
- All-In APR
- Electronic Storage
- Proposals Not
Adopted
Today’s Topics
History of Disclosures
About the CFPB
Mortgage Rules
- Service Providers
- QM / ATR
- Integrated Disclosures
Final Rule
Loan Estimate
- Refinance
Closing Disclosure
- Purchase – Buyer
- Purchase - Seller
Resources
Takeaways
What Lies Ahead?
Q & A
44© Copyright Stewart 2014
Takeaways
� Be Proactive
�Discuss the issues
� Identify process changes
� Plan for the 3-Day Rule
� Print the new forms from stewart.com/cfpb
� Practice with your team
� Invite your compliance officer to join us
� Partner with Stewart
![Page 45: CFPB STC Finalized Rule on Integrated Disclosures](https://reader034.fdocuments.us/reader034/viewer/2022051818/54b5e3e44a7959e4058b456f/html5/thumbnails/45.jpg)
- About the CFPB
- Effective Date
- Loan Estimate
- Closing Disclosure
- Delivery Alternatives
- Three-Day Rule
- All-In APR
- Electronic Storage
- Proposals Not
Adopted
Today’s Topics
History of Disclosures
About the CFPB
Mortgage Rules
- Service Providers
- QM / ATR
- Integrated Disclosures
Final Rule
Loan Estimate
- Refinance
Closing Disclosure
- Purchase – Buyer
- Purchase - Seller
Resources
Takeaways
What Lies Ahead?
Q & A
45© Copyright Stewart 2014
What lies ahead?
![Page 46: CFPB STC Finalized Rule on Integrated Disclosures](https://reader034.fdocuments.us/reader034/viewer/2022051818/54b5e3e44a7959e4058b456f/html5/thumbnails/46.jpg)
- About the CFPB
- Effective Date
- Loan Estimate
- Closing Disclosure
- Delivery Alternatives
- Three-Day Rule
- All-In APR
- Electronic Storage
- Proposals Not
Adopted
Today’s Topics
History of Disclosures
About the CFPB
Mortgage Rules
- Service Providers
- QM / ATR
- Integrated Disclosures
Final Rule
Loan Estimate
- Refinance
Closing Disclosure
- Purchase – Buyer
- Purchase - Seller
Resources
Takeaways
What Lies Ahead?
Q & A
46© Copyright Stewart 2014
Questions?
Q&A
![Page 47: CFPB STC Finalized Rule on Integrated Disclosures](https://reader034.fdocuments.us/reader034/viewer/2022051818/54b5e3e44a7959e4058b456f/html5/thumbnails/47.jpg)
- About the CFPB
- Effective Date
- Loan Estimate
- Closing Disclosure
- Delivery Alternatives
- Three-Day Rule
- All-In APR
- Electronic Storage
- Proposals Not
Adopted
Today’s Topics
History of Disclosures
About the CFPB
Mortgage Rules
- Service Providers
- QM / ATR
- Integrated Disclosures
Final Rule
Loan Estimate
- Refinance
Closing Disclosure
- Purchase – Buyer
- Purchase - Seller
Resources
Takeaways
What Lies Ahead?
Q & A
47© Copyright Stewart 2014
Thank You!