In October, the CFPB proposed two modifications to the Truth in Lending Act-Real Estate Settlement Procedures Act (TILA-RESPA) integrated disclosures final rule. The comment period closed on Nov. 10, 2014.
The effective date for the TILARESPA rule remains Aug. 1, 2015. According to CFPB, “We’re proposing these changes now so that there’s plenty of time to consider these changes while implementation decisions are being made, and we do not think that the proposed changes will affect the industry’s ability to implement the rules on time.”
The first proposed change involves an adjustment to the timing requirements for revised Loan Estimates when the consumer locks in an interest rate or extends a rate lock after the initial disclosures have been provided. The proposal would relax the timing requirement to permit creditors to provide a revised disclosure no later than the next business day after the date the rate is locked—instead of the same date, as is currently required.
“After considering feedback from stakeholders on this requirement, we think that such a short turnaround might be challenging for creditors that currently allow consumers to lock interest rates late in the day or after business hours,” the CFPB said. “This could result in creditors only allowing consumers to lock interest rates during business hours or even early in the day (e.g., before noon).”
Next, the CFPB proposed a minor addition to the Loan Estimate form. Construction loans often take longer to settle than other loans, and the estimated charges can change when more than 60 days pass. The proposal would create a space on the Loan Estimate form where creditors could include language informing consumers they may receive a revised Loan Estimate for a construction loan that is expected to take more than 60 days to settle.
In addition, the CFPB proposed an amendment to the 2013 Loan Originator final rule to provide for placement of the Nationwide Mortgage Licensing System & Registry (NMLSR) ID on the integrated disclosures. The proposal also would make a few minor technical changes to clarify elements of the rule.