The CFPB recently published guidance (the Guide) to assist mortgage originators and settlement service providers in completing the Loan Estimate and Closing Disclosure forms required under the RESPA-TILA Integrated Disclosure Rule (the Rule). The Guide provides step-by-step instructions that industry participants can follow when completing each page of the required forms. The Rule becomes effective August 1, 2015.
The Guide is written in similar detail and style to the Small Entity Compliance Guide issued last month. Each page of the Loan Estimate (3 pages) and Closing Disclosure (5 pages) receives a section-by-section breakdown of the required disclosures and provides illustrative examples of how to complete the necessary fields. Importantly, the CFPB provides guidance on how to make essential calculations. Generally, each section is accompanied by citations to the Rule and examples of various scenarios that could arise during form completion. The Guide spans 96 pages, highlighting the complexity of the Rule and its requirements for completing the Loan Estimate and Closing Disclosure.