Monday, July 23, 2012

CFPB Proposed RESPA-TILA Integration Rule

On July 9, the Consumer Financial Protection Bureau (CFPB) releases its Real Estate Settlement Procedures/Truth in Lending Act (RESPA-TILA) integration rule.

The proposed rule would establish new forms including, a "Loan Estimate," which would combine HUD's good faith estimate and the early TILA disclosures and a "Closing Disclosure" combining HUD-1 and revised TILA disclosures.

The proposed rule would establish several important rule changes, including a mandatory three-day waiting period between the provision of the Closing Disclosure and closing; a new "all-in APR" calculation for the finance charge; and new zero tolerances for services provided by a lender or its affiliates.

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