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CU Compliance Connection

CU Compliance Connection. Integrated Disclosures. Integrated Mortgage Disclosures. Integrated Mortgage Disclosures. The TILA-RESPA rule does not apply to: HELOCs; Reverse mortgages; Mortgages secured by a mobile home or by a dwelling that is not attached to real property; and

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CU Compliance Connection

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  1. CU Compliance Connection Integrated Disclosures

  2. Integrated Mortgage Disclosures

  3. Integrated Mortgage Disclosures • The TILA-RESPA rule does not apply to: • HELOCs; • Reverse mortgages; • Mortgages secured by a mobile home or by a dwelling that is not attached to real property; and • Loans made by a credit union that makes 5 or fewer mortgage loans in a calendar year.

  4. Integrated Mortgage Disclosures • Mortgages now subject to TILA-RESPA rule: • Construction-only loans; • Loans secured by vacant land or by 25 or more acres; and • Credit extended to certain trusts for tax or estate planning purposes.

  5. Integrated Mortgage Disclosures

  6. Integrated Mortgage Disclosures The Loan Estimate must be given to the member NOlater than the third business day after application. An application consists of: • The member’s name; • The member’s income; • Social security number; • The property address; • Estimated property value; and • Mortgage loan amount.

  7. Integrated Mortgage Disclosures • Written list of service providers must be provided within 3 days of application and must: • Identify at least one available settlement service provider for each service; and • State that the member may choose a different provider of that service.

  8. Integrated Mortgage Disclosures

  9. Integrated Mortgage Disclosures The Closing Disclosure must contain the exact same information and be made with headings, content, and format substantially similar to sample form H-25 in the Appendix of the regulation.

  10. Integrated Mortgage Disclosures If the actual terms or costs of the member’s loan transaction change prior to consummation, the credit union must provide a corrected disclosure that contains the actual terms of the transaction and complies with the other requirements of Regulation Z. The credit union may be required to provide an additional three-business-day waiting period prior to loan consummation.

  11. Integrated Mortgage Disclosures The credit union may not impose any fee on a member in connection with the member’s application for a mortgage transaction until the member has received the Loan Estimate and has indicated intent to proceed with the transaction.

  12. Integrated Mortgage Disclosures The credit union must retain copies of the Closing Disclosure for five years after loan consummation. The credit union must retain all other evidence of compliance with the Integrated Disclosure provisions of Regulation Z for three years after consummation of the transaction. State laws may require longer retention periods .

  13. Thank you for joining me for this review of the Integrated Mortgage Disclosure Requirements Stay Tuned… Shawn Wolbert, CIA, CUCE Director CU System Relations 101 S. Washington Square, Suite 900 Lansing, MI 48933-1703 (800) 262-6285 Ext. 486 (734) 658-5427 Mobile Follow me on Twitter – Shawn Wolbert @ Go2CUGuru

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