TILA RESPA Integrated Disclosure

As it Relates to Document Distribution and Delivery Notification

Last update August, 2018

 

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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