The TILA-RESPA rule is effective August 1, 2015.
What is the TILA-RESPA rule about?
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
and a Closing Disclosure.
Implementation and Transition
November of 2013 was a busy time for Federal regulators as they approved final rules combining some of the RESPA rules with other rules still required under the TILA. Congress`s intent being to create an entirely new set of disclosures that, when in place, will provide consumers with information (both new & old) formatted in such a way that provides the utmost in clarity and consumer understanding. The new integrated disclosures will fall into two categories (e.g. "Loan Estimate" and "Closing Disclosure").
The “Who, What, When, Where & Why”
The new integrated disclosures will need to be provided by creditors or mortgage brokers that receive an application from a consumer for a closed-end credit transaction secured by real property on or after August 1, 2015. Creditors are prohibited from using the new disclosures for applications that are received prior to August 1.
While August 1 may seem like a long way off, from a practical standpoint it isn’t and for that reason the construction of the new forms at Oak Tree is well under way to be certain of their availability in time for the new deadline. Given the size of the new documents and the scope of the transaction-specific information that must be mapped or otherwise programmed by your data processor, once you receive your proofs you will want to approve and return them as quickly as possible.
ELECTRONIC FUND TRANSFER AGREEMENT (REGULATION E)
The Electronic Fund Transfer Act is a consumer protection statute that, among other things, limits a consumer’s potential liability for unauthorized transactions made with an approved account access device. The exact amount of the liability is for the most part, determined through the use of a tiered approach that is driven by the time within which a consumer notifies the financial institution.
Data/Loan Processing System Providers
Oak Tree has longstanding relationships with all the predominant Data/Loan Processing System Providers and is working hand-in-hand with them to ensure that your forms will be properly generated on your Credit Union`s system BEFORE the implementation deadline. In fact, we`re already in the testing phase alongside many of the Data/Loan Processing System providers with the vastly different disclosures, with excellent results.
The NCUA is hosting a webinar "Introduction to the New TILA-RESPA Integrated Disclosure (TRID)" on Wednesday, May 27, 2015 at 2p.m. (ET).