On September 8, 2014, the Consumer Financial Protection Bureau (CFPB) issued an updated Small-Entity Compliance Guide to the new TILA-RESPA integrated disclosure rule. This updates the original guide issued in April 2014 to provide additional resources on the rule and to clarify questions related to the seven-day waiting period, Loan Estimate form, and the timing of revisions to the Loan Estimate form. In particular, the CFPB encourages market participants to visit the broad range of resources available on the CFPB’s regulatory implementation website to learn more about compliance with the integrated disclosure rule. Along with other valuable resources, this website was recently updated with a revised guide to the integrated disclosure forms and a sample timeline to illustrate the process and timing of issuing the integrated disclosures.
The Guide also clarifies that the Loan Estimate must be delivered no later than seven business days before the date of consummation, except in circumstances where the borrower experiences a bona-fide personal financial emergency requiring waiver or modification of the waiting period. And the CFPB provides clarification regarding the timing and method for revising the Loan Estimate prior to the closing date. In addition to issuing the updated Guide, the CFPB conducted two webinars in July and August to discuss the integrated disclosure rule and frequently asked questions. These resources provide an excellent way to learn about the intricacies of the integrated disclosure rule and prepare for implementing the integrated disclosure requirements by August 1, 2015.