What is the Tila-Respa Rule?
The TILA- RESPA rule consolidates four existing disclosures required under TILA and RESPA for closed-end credit transactions secured by real property into two forms: A Loan Estimate that must be delivered or placed in the mail no later than the third business day after the creditor receives the consumer’s application, and a Closing Disclosure that must be provided to the consumer at least three business days prior to consummation (Closing). These are provided by the creditor.
The Loan Estimate form must contain a good faith estimate of credit costs and transaction terms. If any information is unknown, the creditor must disclose based on the best information reasonably available at the time the disclosure is provided to the consumer, and use due diligence in obtaining the information.
This change impacts the Financial Institutions and they are responsible for complying. Thus it impacts the title companies’ interaction with them.
What types of Transactions are covered?
Most closed-end consumer credit transactions secured by real property except:
Mortgages secured by a mobile home or by a dwelling that is not attached to real property
When does this start?
This starts on October 3rd for applications taken by the creditor on or after October 3rd.
How will this impact SMPR clients?
Our Good Faith Estimate and our Invoice will contain a notice required under the CFPB starting Monday October 5th. This notice is located on the right had side of both attached documents. This reflects the premium split as CFP Reverse Split Undiscounted Loan Premium. The rest of our notice does not change.
Click below for samples of SMPR Titles updated GFE and Invoice.
Helpful Resources on CFPB:
Watch a brief video on what the TRID rule means to home buyers provided by:
The Three-Day Closing Disclosure Rule: The borrower must receive the CD at least
three days before the closing (consummation). Please see chart below provided by :
These quick and easy sheets will highlight the Top 5 Things that Real Estate Agents and Attorneys need to know about the CFPB changes effective October 3rd. Follow links below:
Provided by Fidelity Title: