The CFPB has released a proposal to revise the Integrated Disclosures Rule. Also included within the proposal is a change to the Loan Originator disclosure requirements under §1026.36 of Regulation Z. In addition to some technical changes, the proposal would make the following changes, if finalized:
- Allow a creditor to provide a revised Loan Estimate no later than the business day after locking a rate. The rule currently requires a revised Loan Estimate be provided the same day as a rate lock.
- Clarify where to disclose that a revised Loan Estimate may be issued anytime prior to 60 days before closing when the transaction involves new construction. The current rule did not provide a place on the Loan Estimate for the disclosure. It’s now proposed that a statement be placed under Other Considerations on the last page of the Estimate.
- Add the Loan Estimate and Closing Disclosure to the documents that must include Creditor and Originator names and NMLSR IDs under §1026.36(g).
Comments are due by November 10th.
Wanting to learn more about TRID Compliance? Learn more about the TILA-RESPA Integrated Disclosures rule here.
Diane joined Banker’s Compliance Consulting with over 10 years of compliance experience and over 15 years of experience within the financial industry. Diane is a Certified Regulatory Compliance Manager (CRCM) and has a Bachelor’s Degree in Sociology with a concentration in Criminal Justice. She is a graduate of the Schools of Banking Compliance School and has participated in various other training opportunities throughout her career. Diane understands firsthand the struggles banks face in building and maintaining successful compliance programs. Her experience and common sense approach to consumer compliance is a great asset to our clients.
Diane and her husband have two kids who keep them busy. She enjoys running and other sports and is a big Bugs Bunny fan! She’s a bit crazy in that she does enjoy reading some of these regulations and she’s a “crazy cat lady!” Her cat tales are hilarious!