Guide to the CFPB's Mortgage Disclosure Requirements PDF Format

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Citing its awareness of the difficulty of putting integrated disclosure processes into place, the Consumer Financial Protection Bureau assures that it is still conducting exams with leniency for “good-faith” efforts to comply with the TRID rule that went into effect in October 2015. But legal experts with CFPB backgrounds suggest that enough time has passed that more stringent enforcement is probably underway.

The “good-faith” approach might still pay off, though. Companies that are vigilant in their compliance efforts, including those that are undertaking robust quality control, could avoid heavy liability, at least with regard to agency action, the experts say.

Learn all about the Loan Estimate and Closing Disclosure forms and the rules around them in IMF’s Guide to the CFPB’s Mortgage Disclosure Requirements. The report covers such topics as timing of disclosures, recordkeeping, liability and redisclosures. It also includes a lender perspective section that spotlights important points in the rules where major process changes might be required.

Contents include:

Disclosure Requirements

• Definition of a Loan Application

• Limitation on Fees and Verification

• Permissible Changes Between Disclosures

• Exceptions to Permitted Changes

• Recordkeeping Requirements

• Liability Under Disclosure Laws

• Electronic Disclosure Requirements

• Mortgage Servicing Transfer and Partial Payment Notices

Loan Estimate

• Itemized Disclosure of Individual Charges

• Disclosure of Broker Compensation

• Re-Disclosure

Closing Disclosure

• Escrows

• Permitted Changes After Closing

Lender Perspective

• Intent to Proceed

• Locking the Interest Rate After Disclosure

• Timing and Accuracy on Closing Disclosure

• Tolerances as a ‘Moving Target’

• Liability After Foreclosure

• Errors Discovered After Closing