Changes to the Truth in Lending Act: What You Need to Know!
Regulation Z of The Truth in Lending Act (TILA) has undergone important changes that you need to know about when talking to your clients. These changes take effect for all new applications taken on July 30, 2009 and after, apply to ALL types of mortgage loans in ALL 50 states plus the District of Columbia, and could impact the overall timeline of the mortgage loan origination process.
Here are the four key parts of the new regulation you need to know:
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Initial Disclosures. Under the new rules, initial disclosures must be provided to the borrower for all loan types within three (3) business days of when an application is taken or received. Initial disclosures include: the Good Faith Estimate (GFE), Truth in Lending Statement and state-specific disclosures.
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Collection of Up-front Fees. The new regulations prohibit lenders from collecting many up-front fees prior to when the borrower receives the initial disclosures.
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Re-disclosures. If there are changes to a borrower's loan program, loan terms, and/or Annual Percentage Rate (APR), the initial disclosure package must be re-disclosed to the borrower, and it must be received by the borrower at least three (3) business days prior to closing.
- Timing of Loan Closings. Prospect cannot schedule the loan closing until at least seven (7) business days after the initial disclosures are mailed to the borrower. If re-disclosures are needed because of changes to the loan program, terms or APR, the loan closing cannot be scheduled until at least six (6) business days after the re-disclosures are mailed to the borrower.
This notice was provided by Kerry Hogan, Vice President, Bank of America. Kerry is willing to answer your questions.
Kerry Hogan Direct: 703.385.1567
Fax: 866.207.4727
kerry.hogan@bankofamerica.com
Bank of America
1801 K Street NW, 4th Floor
Washington , DC 20006
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