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Wednesday, June 3, 2015

CFPB Changes to Come

New federal rules promulgated by the Consumer Financial Protection Bureau (“CFPB”) are effective October 3, 2015. These rules relate to Integrated Mortgage Disclosures under the Real Estate Settlement Procedures Act (“RESPA”) (Regulation X) and the Truth In Lending Act (“TILA”) (Regulation Z).

The changes that are most relevant for real estate brokers include:

 Definition of loan “application” (12 CFR 1026(a)(2));

 The lender must provide a “Loan Estimate” to Buyer within three days of application (12 CFR 1026.19(e));

 The lender must provide a “Closing Disclosure” to Buyer at least three days before consummation (i.e. the date the Buyer is contractually obligated for the loan) (12 CFR 1026.19(f));

 The lender must provide a revised “Closing Disclosure” for last minute changes to the APR, the addition of a pre-payment penalty, or a change in the loan product at least three days before consummation (i.e. the date the Buyer is contractually obligated for the loan) (12 CFR 19(f)(2)(i)).

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