CFPB Publishes Guide to the TILA-RESPA Loan Estimate and Closing Disclosure Forms
The Consumer Financial Protection Bureau (CFPB) on April 17, 2014 announced the release of a Guide to Completing TILA-RESPA Integrated Disclosure Forms (the Forms Guide). The CFPB states that the purpose of the Forms Guide is to provide instructions for completing the two new integrated TILA-RESPA disclosure forms, the Loan Estimate and Closing Disclosure, and to highlight common situations that may arise when completing the forms. Additionally, as the changes related to the TILA-RESPA Integrated Disclosure Rule may take time, resources, and planning to execute, the CFPB hopes the Forms Guide will help identify some of the necessary changes that may need to be implemented by organizations involved in the origination of closed-end residential mortgage loans. Settlement service providers, software providers, and other companies that serve as business partners to creditors may also find the Forms Guide helpful
The Forms Guide provides a good general overview of both the Loan Estimate Form and the Closing Disclosure Form, providing general requirements for completing each form, including timing requirements and basic definitions. The Forms Guide also covers more specific instructions for completing each section of the forms, including the loan terms, projected payments, costs at closing, and loan estimate sections. In addressing the more specific section requirements, the Forms Guide provides common variables that may affect the completion of the section and discusses the best approach for addressing each variable. The language of the Forms Guide is designed to be simple and user-friendly.
The CFPB designed the Forms Guide to be a companion to the Small Entity Compliance Guide (Compliance Guide) which the CFPB also recently released. The Compliance Guide provides questions and responses related to the new TILA-RESPA Integrated Disclosure Rule in a Frequently Asked Question, plain-language format designed for smaller businesses or entities that may have a limited legal and compliance staff. Both the Forms Guide and the Compliance Guide should assist lenders, settlement service providers, and others in the industry with integrating the TILA-RESPA Integrated Disclosure Rule into their practice.