CFPB Adopts Final Changes To Tila-Respa Integrated Disclosure Rule

Last October, the CFPB proposed changes to the TILA-RESPA Integrated Disclosure Final Rule first issued in November of 2013 and effective August 15, 2015. The proposed changes would have adjusted the timing requirement for giving revised disclosures when the consumer locks in the interest rate after the initial Loan Estimate disclosure has been given, corrected an omission in the original rule to allow certain language relating to new construction loans to be included on the Loan Estimate form, and required NMLSR ID numbers to be shown on the integrated disclosures, along with several technical corrections and wording changes.

Under the integrated disclosure rule as originally issued, a creditor must provide a revised Loan Estimate disclosure re-disclosing interest rate dependent charges and loan terms on the date that the interest rate is locked. The Bureau proposed to allow creditors until the next business day after the rate lock occurs to provide the