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:

  1. The HUD-1 Settlement Statement is being combined with the Truth-in-Lending (TIL) disclosure into one document.
  2. 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.
  3.  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.