1. RESPA-TILA Regulation

2. Background
Since the Consumer Financial Protection Bureau (CFPB) “went live” in July, 2011 it has been issuing new regulations under the Dodd-Frank Act.
One of the biggest undertakings is the Integrated Disclosure Rule published in November, 2013 which combines the disclosure forms from both RESPA and TILA.
The consolidation of multiple forms is intended to reduce paperwork and customer confusion.
The program provides your clients with:
Confidence in knowing what they can comfortably afford
A Conditional Approval Letter they can share with the seller and real estate agent to demonstrate they are a serious and prepared buyer
A timely closing once they find a new home

3. Summary There are 3 main components to the changes:
New definition of an application
Loan Estimate
Closing Disclosure
The program provides your clients with:
Confidence in knowing what they can comfortably afford
A Conditional Approval Letter they can share with the seller and real estate agent to demonstrate they are a serious and prepared buyer
A timely closing once they find a new home

4. Definition of an Application – NEW
The regulation is very prescriptive regarding the items that define an application for the purposes of receiving a Loan Estimate
An application for RESPA-TILA Loan Estimate purposes consists of 6 items:
Name
Income
Social Security Number (for pulling credit)
Property Address
Estimated property value
Mortgage loan amount sought
The program provides your clients with:
Confidence in knowing what they can comfortably afford
A Conditional Approval Letter they can share with the seller and real estate agent to demonstrate they are a serious and prepared buyer
A timely closing once they find a new home
We may collect additional information, but once the 6 items have been collected, a Loan Estimate must be issued within 3 business days and not later than 7 business days before closing

5. Loan Estimate - NEW
Replaces the Good Faith Estimate (GFE), Early Truth-In- Lending, Appraisal Notice and Transfer of Servicing Notice
Must be provided within 3 business days of application
Has an expiration date of 10 business days after issuance unless the consumer gives intent to proceed (ITP)
The program provides your clients with:
Confidence in knowing what they can comfortably afford
A Conditional Approval Letter they can share with the seller and real estate agent to demonstrate they are a serious and prepared buyer
A timely closing once they find a new home

6. Loan Estimate - NEW
The consumer must give ITP before any fees or credit card information can be collected
Fees shown on the Loan Estimate are binding unless there is a Change in Circumstances or the consumer requests a change.
The program provides your clients with:
Confidence in knowing what they can comfortably afford
A Conditional Approval Letter they can share with the seller and real estate agent to demonstrate they are a serious and prepared buyer
A timely closing once they find a new home

7. Closing Disclosure - NEW
Replaces the HUD-1, Final Truth-In-Lending, and Escrow Disclosure
Customer must receive at least 3 business days before loan closing
Gives customer time to review and understand all costs prior to closing
3 day review period may not be shortened or waived
The program provides your clients with:
Confidence in knowing what they can comfortably afford
A Conditional Approval Letter they can share with the seller and real estate agent to demonstrate they are a serious and prepared buyer
A timely closing once they find a new home

8. Closing Disclosure - NEW
Creditor is responsible for ensuring the Closing Disclosure is accurate and provided in a timely manner
Creditor must provide complete and accurate terms of the transaction
Previously provided by settlement agent on HUD-1 statement
Contact Information section of the Closing Disclosure requires each real estate broker and settlement agent name, address, state license ID, primary contact person and that person’s state license ID, and phone.
The program provides your clients with:
Confidence in knowing what they can comfortably afford
A Conditional Approval Letter they can share with the seller and real estate agent to demonstrate they are a serious and prepared buyer
A timely closing once they find a new home

9. Additional Information
The borrower and the seller closing disclosures will be provided separately
Some seller information that also pertains to our customer’s transaction will also be on the borrower’s document
Changes apply to mortgage applications submitted on or after August 1st, 2015
Rules apply to all closed-end residential mortgage loans
Not applicable to Home Equity lines of credit
The program provides your clients with:
Confidence in knowing what they can comfortably afford
A Conditional Approval Letter they can share with the seller and real estate agent to demonstrate they are a serious and prepared buyer
A timely closing once they find a new home

10. Disclosures
This material is intended for real estate and home lending professionals only and not for distribution to consumers. This document is not an advertisement for consumer credit as defined in 12 CFR (a)(2).
This material has been prepared for informational and educational purposes only.  It is not intended to provide, and should not be relied upon for, investment, accounting, legal or tax advice.
Home lending products offered by JPMorgan Chase Bank, N.A.
©2015 JPMorgan Chase & Co.

11. APPENDIX 

12. Loan Estimate – Example of completed form:
Closing Disclosure – Example of completed form:
Source: CFPB website: