TILA/RESPA Integrated Disclosure “Bootcamp” Series Course Modules

You'll receive on-demand access to 15 online video modules covering the following TILA/RESPA Integrated Disclosure topics:

Earn NAFCU Certified Compliance Officer credits NCCOs earn 7.5 CEUs total for the series

  1. The Basics – Overview, Scope & Definitions (0.5 CEUs)
    1. Integrated mortgage disclosures
    2. Applications received on or after August 1, 2015
    3. No 'small creditor" exemptions
    4. Which loans are covered?
    5. New definition of application
    6. Two definitions of business day
  2. The Basics – Timing for Delivering Disclosures (0.5 CEUs)
    1. Very specific timing requirements
    2. Impact of new application definition
    3. Document changed circumstances
    4. New timeframe for closing disclosures
  3. Pre-Disclosure Restrictions (0.5 CEUs)
    1. Shopping the loan estimate
    2. Six pieces of information = application
    3. Limitation on fees
    4. Limitation on verifying information
    5. Must obtain and document intent to proceed
  4. Written Estimate of Terms or Costs (0.25 CEUs)
    1. Review current worksheets/estimates
    2. Include required disclosures on all worksheets and written estimates of terms or costs
    3. Verify estimates are not similar to loan estimate or closing disclosure
  5. Written List of Settlement Service Providers (0.25 CEUs)
    1. Written list – key for tolerance levels
      1. Must "permit the consumer to shop"
      2. 10% cumulative tolerance applies if consumer can choose their own settlement service provider
      3. No tolerance if consumer selects own provider
    2. Timing is same as loan estimate
    3. Review settlement service providers
  6. Tolerance Levels (0.5 CEUs)
    1. Good faith requirement
    2. Zero tolerance
    3. 10% cumulative tolerance
    4. No tolerance (can increase)
    5. Permitting a consumer to shop
      1. Written list of service providers
    6. Analyze credit union's current fees and charges
  7. Loan Estimate – Page 1 (0.75 CEUs)
    1. Strict formatting and content requirements
    2. Dynamic requirements
      1. Depends on specific transaction type
      2. Depends on specific transaction terms
    3. The more complex the mortgage loan the more complicated the loan estimate disclosure
    4. Start with the basics
      1. Fixed rate purchase; fixed rate refinance
  8. Loan Estimate – Page 2 (0.5 CEUs)
    1. Strict formatting and content requirements
    2. Loan costs table and other costs table
      1. Certain disclosures are "hard coded"
      2. Leave certain sections blank
      3. Specific order required; general terminology
    3. Calculating cash to close
      1. Alternative table for transaction without a seller
    4. AP and AIR Tables – only include if applicable
  9. Loan Estimate – Page 3 (0.25 CEUs)
    1. Contact information
      1. Must include specific phone and email information
    2. Comparisons – "shop the loan estimate"
      1. New "in five years" disclosure
      2. New "TIP" disclosure
    3. Consolidation of other disclosures
      1. Liability after foreclosure – refinances only
    4. Confirm receipt
  10. Closing Disclosure – Pages 1 & 2 (0.75 CEUs)
    1. Closing disclosure tracks loan estimate
      1. Loan terms; projected payments
    2. Alternatives for transactions without sellers
    3. Closing cost details
      1. Loan costs table and other costs table
    4. Cross-references to loan estimate
    5. Lender credit – tolerance cure refund
  11. Closing Disclosure – Page 3 (0.5 CEUs)
    1. Page 3 variations
      1. Seller or no seller
    2. Calculating cash to close
      1. Comparison table – between loan estimate and final
        1. Yes or no and details
        2. Lender credits for tolerance violations
    3. Summaries of transactions
    4. Separate payoff and payments table (no seller)
  12. Closing Disclosure – Pages 4 & 5 (0.75 CEUs)
    1. Content heavy pages
      1. Key facts regarding the loan must be provided
    2. Escrow Account Disclosure
      1. Must calculate estimate of property costs during first year even if no escrow account will be established
    3. AP and AIR Tables, as applicable
    4. Loan calculations
    5. Other disclosures (may vary depending on loan)
    6. Specific contact information
  13. Escrow Closing Notice (0.5 CEUs)
    1. New disclosures requirement
    2. Scope differs from other requirements
    3. Which of your loan products are impacted?
    4. Review current escrow closure process
      1. Audit for compliance with HPML Escrow Requirements
    5. Adopt new procedures for Escrow Closure Notice
      1. Timing differs depending on who initiates cancellation
    6. Utilize H-29 Model Form
  14. Post-Consummation Partial Payment Disclosure (0.25 CEUs)
    1. Review scope of new disclosure
    2. Which of your loan products are impacted?
    3. Verify CU's current partial payment policy
    4. Review existing transfer notice
      1. Has CU obtained ownership of mortgages since January 2010? Was the notice sent?
      2. Update mortgage transfer notice to include new partial payments disclosure
  15. Frequently-Asked-Questions (FAQs) (0.5 CEUs)
    1. Document, document, document
      1. Show your work, create an audit trail
    2. Identify the issue, conduct research, document the credit union's decision
      1. If necessary, obtain further information
    3. Talk to other credit unions
      1. Verify their analysis and conclusions
    4. Share answers to FAQs with other staff

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