Jiji BahurWith just four months until the Aug. 1 implementation deadline, it’s no surprise that the CFPB’s Truth in Lending Act/Real Estate Settlement Procedures Act (TILA-RESPA) integrated mortgage disclosure rule is one of NCUA’s supervisory priorities for 2015. With the implementation deadline right around the corner, credit unions are scrambling to ensure all bases are covered for compliance with this 1,900-page final rule and the recent TILA-RESPA amendments on rate locks, new construction loans and placement of the NMLSR ID, which all have the same implementation deadline.

The TILA-RESPA rule requires loan originators who receive an application on or after Aug. 1, 2015, to provide consumers a loan estimate form that combines the initial TILA disclosure and the Good Faith Estimate, no later than three business days after receiving a consumer’s mortgage application. The rule also requires loan originators to provide consumers a Closing Disclosure form, which combines the final TILA disclosure and the HUD-1 Settlement Statement, at least three business days prior to consummation of the mortgage. It seems easy enough, but there’s more to it, including difficult-to-understand timing and delivery requirements and other practical implementation issues that go beyond the form content requirements.

To ensure timely compliance with the TILA-RESPA rule, it is imperative that credit unions have a plan of action for addressing the many requirements of the rule and also the steps to implement it. A good starting point is assignment of a project manager or implementation team to create and track the compliance plan. In addition, create an implementation map and timeline to organize the requirements and stages of integration, especially since implementation of TILA-RESPA is highly software-dependent and will require credit unions to work closely with vendors to ensure they are on track with integration. 

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