TILA RESPA Integrated Disclosure, or more commonly, TRID

On October 3rd, 2015 the Consumer Financial Protection Bureau or CFPB is replacing four existing disclosure forms required under federal law into two new documents the Loan Estimate and the Closing Disclosure.  These new forms will make it easier for the borrower to understand the loan they will be receiving and they will be better prepared to make more informed financial decisions.  In addition, here are some new terms that you will need to be familiar with:

Lender = Creditor
Borrower = Consumer
Tolerances = Variances
Closing/Settlement = Consummation (the date the consumer signs the note)
Settlement Agent = Settlement Service Provider

The new disclosures are explained below in more detail.

Loan Estimate

The Loan Estimate is replacing the Good Faith Estimate (GFE) and the initial Truth-in-Lending disclosure (initial TIL).  These forms have been combined into this new form, the Loan Estimate.

Buyers will get a Loan Estimate no later than the third business day after they submit a loan application.

The new form is designed to highlight key terms to enable borrowers to shop around for the best deals and more importantly it is designed to be user-friendly.

The Creditor or Loan Broker will provide the creditor with the Loan Estimate.

Closing Disclosure

The Closing Disclosure is replacing the HUD-1 and final Truth-in-Lending disclosure (final TIL and, together with the initial TIL, the Truth-in-Lending forms).  These forms have been combined into this new form, now called the Closing Disclosure.

Consumers must get this form provided to them at least three business days before consummation of the loan.  Consummation is the date that a consumer becomes contractually obligated to the creditor on the loan (i.e., the day they sign the note.)  If the form is mailed, couriered or emailed, the lender must allow an extra three business days on top of that.  This means that the closing cannot occur for at least six business days after the lender or Settlement Service Provider sends out the completed Closing Disclosure.

The Creditor or Settlement Service provider will provide the creditor with the Closing Disclosure.

Loan Estimate variances from Closing Disclosure

Keep in mind that the Closing Disclosure can change from the Loan Estimate.  Variances, formerly known as tolerances, will force more fees into the 0% and 10% categories. Lenders may have greater responsibility imposed on them for the amount their partners charge.

What type of transactions need the new disclosures?

These new disclosures and rules apply to residential properties that include a mortgage as part of a sale or refinance transaction.  They do not apply to HELOCs, reverse mortgages or mortgages secured by a mobile home or by a dwelling that is not attached to real property (i.e., land), commercial or all-cash transactions.

What is three business day rule?

Every working day including Saturdays.  The exceptions will be Sundays and legal holidays.

Riva Title Company Is Ready 
Riva Title Company will be ready for the new CFPB changes.  We will comply with all CFPB regulations and we will be ready to get the final closing information to the Creditor at least 10 days before the closing date so that the Creditor can complete the Closing Disclosure in time to get it out six days before the scheduled closing.
5900 SW 73rd Street
Suite 208
South Miami, FL  33143
Phone 786-787-7888
Fax 305-448-4500