Venable CFPB Update: Getting Ready for August 2015: What Is a Mortgage Application?

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Explore:  CFPB Mortgages TILA

On August 1, 2015, mortgage lenders will be required to provide applicants with a new, integrated disclosure, the Loan Estimate (which replaces the “Early” Truth in Lending disclosure), and the Good Faith Estimate. To prepare for when this regulation goes into effect, this update reviews what will constitute an “application” for a mortgage loan, and what that means to mortgage lenders, mortgage brokers, and lead generators. Note that this new definition will not apply to loan products other than mortgage loans.

At present, neither the Truth in Lending Act (TILA) nor the Real Estate Settlement Procedures Act (RESPA) defines the term “application.” Regulation X, however, defines an application as...

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