ConsumerFinancialProtectionBureau

Five Things You Need to Know Before August 2015

Five Things You Need to Know Before August 2015

• Lender must deliver within three business days of the lender’s receipt of an “application”

• Application – automatically occurs when lender receives six pieces of information:

• Borrower(s) Name(s)• Income• Social Security Number(s)• Property Address• Estimated Value of Property• Mortgage Loan Amount

Receiving the Loan Estimate

The Loan Estimate

New Terms• Creditor = A Loan Originator, Lender or Mortgage Broker

• Consummation = The day the borrower becomes legally obligated to repay the debt – the date of the signing of the loan documents

• Business Day = A day on which the creditor’s offices are open to the public for carrying on substantially all of its business functions

• For purposes of rescission under TILA – all calendar days EXCEPT Sundays and Legal Public Holidays

• TRID – TILA-RESPA Integrated Disclosure

Closing Disclosure

Five Things You Need to Know Before August 2015

Five Things to Know:

CFPB New Timeline

Closing Information

Loan Terms

Projected Payments

Costs at Closing

Closing Disclosure| pg.1

8/14/20158/18/20158/19/2015

Closing Information

Customer Received Disclosure

Customer Signed (Consummation)

Escrow Cuts Checks

Loan Costs

Other Costs

Closing Disclosure| pg.2

Calculating Cash to Close

Summaries of Transactions

Closing Disclosure| pg.3

Loan Disclosures – contains various lender disclosures required under TILA, RESPA or Dodd-Frank

Closing Disclosure| pg.4

Loan Calculations Various specific Loan calculations, including Finance Charge and APR, required under TILA, RESPA or Dodd-Frank

Other Disclosures Various lender disclosures required under TILA, RESPA or Dodd-Frank

Contact Information

Confirm Receipt Signatures

Closing Disclosure| pg.5

Only a few changes will require another 3-day waiting period –

• Change in the loan programExample – moving from fixed rate to an adjustable rate loan

• Changes to Annual Percentage Rate (APR) greater than 1/8 %Applies only to increases in APR items , other increases do not trigger a new disclosure with waiting period.

Caution – other increases may still cause tolerance violationsThe addition of a prepayment penalty fee after the initial disclosure But , all changes require a new Closing Disclosure to be prepared and delivered at or before “consummation”.

Changes to initial Closing Disclosure after delivery

Closing Disclosure

Five Things You Need to Know Before August 2015

Five Things to Know:Which loans are exempt?

Reverse Mortgage Home Equity Line of Credit Mobile Home Only Loans Creditors that originate less than 5

loans in a calendar year

ConsumerFinancialProtectionBureau

Q&A

Thank you.

www.ChicagoTitleCFPB.com

www.CFPB.gov