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WBK Industry News - Federal Regulatory Developments

CFPB Updates Know Before You Owe Mortgage Disclosure Rule Guides in a Revised Small Entity Compliance Guide

Updates to incorporating changes and clarifications from the July 7, 2017 amendments to the TILA-RESPA Final Rule that were published on August 11, 2017 are addressed in the newly revised October 2017 TILA-RESPA Integrated Disclosure Rule – Small Entity Compliance Guide (Version 5.0).  Version 5.0 specifically lists the following clarifications and changes:

  • Requirements and guidance for tolerances in the good faith analysis (Section 7);
  • Requirements and guidance for providing revised Loan Estimates (Section 8);
  • Requirements for permitting a consumer to shop and providing the written list of service providers (Sections 7.3, 7.5, 7.6, 7.7, 7.11, and 8.7);
  • Coverage for cooperative units, trusts, and the partial exemption for certain housing assistance loans (Section 4);
  • Guidance on lender and seller credits, including impacts to the good faith analysis (Sections 7.13 and 13.10);
  • Tolerance standards applicable to the Total of Payments (Sections 10.11);
  • Guidance on disclosing transactions with a simultaneous subordinate-lien loan (Sections 10.8, 11.5, and 13.9);
  • Requirements for providing corrected Closing Disclosures for changes to per diem interest (Section 12.7);
  • Disclosing cures for tolerance violations (Sections 7.14, 10.13, 12.10);
  • Guidance on sharing disclosures with third parties (Section 13.8);
  • Guidance on construction loans (Sections 4.1, 5.6, 5.9, 6.4, 8.1, 8.10, 10.7, 14);
  • The safe harbor provided by correct use of sample forms (Sections 5.2 and 10.3);
  • Updated effective date requirements for 2017 amendments (Section 1 and 3);
  • Standardization of coverage of cooperative units throughout; and
  • Miscellaneous administrative changes.