New Truth In Lending Act Disclosure Requirements Home Buyers Should Know About

Real Estate Agent with William Raveis Legends Realty Group 30PA1082583

Revisions to the Truth In Lending Acts disclosure requirements took place July 30, 2009.  Many believethe new requirements will be a challenge for lenders to comply and also may cause delays for closings.  Only time will tell, but once again the process has become more complicated.  The new revisions are as follows.


• The new requirements apply to all mortgages secured by a borrower's home, including

primary and second homes and refinancings. Investor loans continue to be exempt.

• Lenders must give good faith estimates of mortgage loan costs within 3 business days

after the consumer applies for a loan (early disclosure). The lender may not collect any

fees before the disclosure is provided, except for a reasonable fee for obtaining a credit


• The closing may not take place until expiration of a 7 day waiting period after the

consumer receives the early disclosure.

• Consumers may shorten or waive the 3‐day and/or 7‐day waiting periods for a "bona


personal financial emergency," but only after receiving an accurate TILA disclosure.

In the final rule's preamble, the Fed stated that it "believes waivers should not be used

routinely to expedite consummation for reasons of convenience." The Fed decided not

to insulate lenders from liability even where a consumer modifies or waives the waiting


• If the annual percentage rate (APR) changes by more than 0.125 percent, the lender

must provide a corrected disclosure to the borrower and wait an additional 3 business

days before closing the loan. The APR includes not only the interest rate on the loan but

certain other costs related to settlement, so it will be important for any fees that affect

the APR to be as accurate as possible, as early as possible, to minimize the need for a

corrected TILA disclosure.

This is only a summary for the full report please visit this link (you may have to cut and paste it into your browser)


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New York Westchester County
first time buyers
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Christopher Pagli

"I Stay Open Until You Close"
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