TILA RESPA Integrated Disclosure

As it Relates to Document Distribution and Delivery Notification

Last update August, 2018

 

Common Acronyms: 

TILA – Truth in Lending Act

RESPA – Real Estate Settlement Procedure Act

TRID – TILA RESPA Integrated Disclosure

Why does this affect you?

The TRID rule itself is primarily concerned with the creation and delivery of two new documents: the Loan Estimate, which replaced the initial Truth in Lending and the Good Faith Estimate forms, and the Closing Disclosure, which replaced the closing Truth in Lending and HUD-1 forms.

 

What does TRID require?

Timing becomes a critical component and a challenge.

  • The Loan Estimate is required to be delivered to the customer within three business days of the application’s completion.
  • The Closing Disclosure is required to be provided to the customer three business days prior to consummation of the loan.
  • Finalized Closing Disclosure (TILA), must be sent within 45 days on closing (RESPA)
  • Goodbye Letter (only if mortgage loan is sold to another bank) within 15 days prior to transfer

 

Questions to be asked

  • How are your vendors handling these changes?
  • How will this affect the way you work with your settlement agents?
  • Do you have a way to receive and distribute documents to ensure the privacy of personal non-public information?
  • Do you have a way to confirm delivery of documents sent to the borrower to ensure good standing of the time requirements?

 

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To view the complete legislation/requirements, and/or to get further information, please see:

http://files.consumerfinance.gov/f/201508_cfpb_tila-respa-integrated-disclosure-rule.pdf
http://files.consumerfinance.gov/f/201508_cfpb_tila-respa-integration-disclosure-timeline-example.pdf
https://www.icba.org/files/ICBASites/PDFs/TILARESPAIntegratedDisclosureSummary.pdf
http://www.consumerfinance.gov/regulatory-implementation/tila-respa/

 

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