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The Federal Reserve Board on May 8 approved revisions to its Regulation Z mortgage disclosure requirements that implement provisions of the July 2008 Mortgage Disclosure Improvement Act. The revisions go into effect for dwelling-secured mortgage loan applications received on or after July 30, 2009. Under the MDIA, lenders are required to provide good-faith estimates of mortgage loan costs, called early disclosures, within three business days after receiving a mortgage loan application and before any fees are collected from the consumer, other than a reasonable credit check fee. The rules also enact MDIA rules that impose a seven business day waiting period between the early disclosure and closing date. Additionally, lenders must provide new disclosures, including a revised annual percentage rate if the existing interest rate significantly changes between the time the early disclosure is provided and the closing date. CUNA will examine the final rule to determine whether concerns the trade group addressed in its comment letter have been addressed, said Assistant General Counsel Jeffrey Bloch. CUNA had suggested the timing restrictions be relaxed if the changed APR resulted in an interest rate reduction and that the Fed replace the two definitions of “business day” that were in the proposed rule with a single definition.

Peter Westerman

Credit Union Times

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