Today, the National Association of Independent Land Title Agents (NAILTA) submitted formal public comment concerning the CFPB’s Integrated Disclosure Rule under the Dodd-Frank Act.
In summary, NAILTA’s Response to the CFPB on New HUD/TIL Disclosures:
The proposed rule making can be found by clicking here. A summary of the rule can be found by clicking here. The most important points of the proposed rule relate to the following:
- The HUD-1 Settlement Statement is being combined with the Truth-in-Lending (TIL) disclosure into one document.
- The lender is required to give consumers the new combined HUD-1 at least three business days before the consumer closes on the loan. Any changes between that time and closing requires an additional three day period and new forms.
- Who must provide the new combined HUD-1 Settlement Statement is also at issue. CFPB is proposing two options: (1) the lender would be responsible for delivering the HUD-1 to the consumer; and, (2) the settlement agent is responsible, but the lender remains responsible for the accuracy of the form.
