CFPB STC Finalized Rule on Integrated Disclosures

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CFPB STC Finalized Rule on Integrated Disclosures

  1. 1. Understanding the CFPB Final Rule on Integrated Disclosures Presented by: Noah Blanton January, 2014 1
  2. 2. Disclaimer Today’s Topics - About the CFPB -History of Disclosures Effective Date About the CFPB - Loan Estimate Mortgage Rules - Closing Disclosure - Service Providers - Delivery Alternatives The information in this presentation, event and/or printed material is provided for informational purposes only. None of the materials or opinions is offered, or should be construed, as legal advice. Communication of information by or through these means and your receipt or use of such information is not to be construed as legal advice or to constitute an attorneyclient relationship. - QM / ATR - - Three-DayDisclosures Rule Integrated -Final Rule All-In APR -Loan Estimate Electronic Storage Refinance - - Proposals Not Closing Disclosure Adopted - Purchase – Buyer - Purchase - Seller Resources Takeaways You should not act or rely upon information contained in these materials without specifically seeking professional legal advice. Additional resources that may be referenced in the following presentation or materials are offered merely as a convenience to participants with no guarantees made as to the applicability or validity of the third-party content. We do not take any responsibility for the content, accuracy or timeliness of referenced websites, articles, books, events, etc.; nor do we endorse any commercial products that may be advertised or available on those sites. What Lies Ahead? Q&A Stewart endeavors to comply with all applicable legal and ethical requirements when providing information to industry participants. © Copyright Stewart 2014 2
  3. 3. History of Disclosures – Truth-in-Lending Today’s Topics - About the CFPB -History of Disclosures Effective Date About the CFPB - Loan Estimate Mortgage Rules Truth-in-Lending Act (TILA) of 1968 Implemented by Federal Reserve Board - Closing Disclosure - Service Providers - Delivery Alternatives - QM / ATR - - Three-DayDisclosures Rule Integrated -Final Rule All-In APR -Loan Estimate Electronic Storage Refinance - - Proposals Not Closing Disclosure Adopted Promulgated Regulation Z Created Truth-in-Lending Statement Discloses the following: - Purchase – Buyer - Purchase - Seller Cost of credit Resources Takeaways Repayment terms of mortgage What Lies Ahead? Q&A Annual percentage rate (APR) Loan rate Fees amortized over expected life of loan Discloses finance charges, amount financed, total number of payments, whether interest can change, whether loan can be refinanced © Copyright Stewart 2014 3
  4. 4. History of Disclosures - RESPA Today’s Topics - About the CFPB -History of Disclosures Effective Date Real Estate Settlement Procedures Act of 1974 About the CFPB - Loan Estimate Mortgage Rules - Closing Disclosure - Service Providers RESPA was implemented by HUD - Delivery Alternatives - QM / ATR - - Three-DayDisclosures Rule Integrated Promulgated Regulation X -Final Rule All-In APR -Loan Estimate Electronic Storage Refinance - - Proposals Not Closing Disclosure Adopted - Purchase – Buyer Created Good Faith Estimate Standardized disclosures of closing costs - Purchase - Seller Resources Takeaways What Lies Ahead? Q&A Included costs associated with mortgages HUD-1 and GFE modified in 2010 © Copyright Stewart 2014 4
  5. 5. The CFPB Timeline Today’s Topics - About the CFPB 2007 2008 2009 2010 2011 2012 2013 -History of Disclosures Effective Date About the CFPB - Loan Estimate Mortgage Rules - Closing Disclosure - Service Providers - Delivery Alternatives The market peaked in 2007…. - QM / ATR - - Three-DayDisclosures Rule Integrated -Final Rule All-In APR -Loan Estimate Electronic Storage Refinance - - Proposals Not Closing Disclosure Adopted - Purchase – Buyer - Purchase - Seller Resources Takeaways What Lies Ahead? Q&A © Copyright Stewart 2014 5
  6. 6. The CFPB Timeline Today’s Topics - About the CFPB 2007 2008 2009 2010 2011 2012 2013 -History of Disclosures Effective Date About the CFPB - Loan Estimate Mortgage Rules - Closing Disclosure - Service Providers - Delivery Alternatives Officially dubbed “Financial Collapse” in 2008 - QM / ATR - - Three-DayDisclosures Rule Integrated -Final Rule All-In APR -Loan Estimate Electronic Storage Refinance - - Proposals Not Closing Disclosure Adopted - Purchase – Buyer - Purchase - Seller Resources Takeaways What Lies Ahead? Q&A © Copyright Stewart 2014 6
  7. 7. The CFPB Timeline Today’s Topics - About the CFPB 2007 2008 2009 2010 2011 2012 2013 -History of Disclosures Effective Date About the CFPB - Loan Estimate Mortgage Rules - Closing Disclosure - Service Providers - Delivery Alternatives - QM / ATR - - Three-DayDisclosures Rule Integrated -Final Rule All-In APR -Loan Estimate Electronic Storage Refinance - - Proposals Not Closing Disclosure Adopted - Purchase – Buyer - Purchase - Seller Resources Takeaways What Lies Ahead? Q&A The push for financial regulatory reform began in 2009 © Copyright Stewart 2014 7
  8. 8. The CFPB Timeline Today’s Topics - About the CFPB 2007 2008 2009 2010 2011 2012 2013 -History of Disclosures Effective Date About the CFPB - Loan Estimate Mortgage Rules - Closing Disclosure - Service Providers - Delivery Alternatives - QM / ATR - - Three-DayDisclosures Rule Integrated -Final Rule All-In APR -Loan Estimate Electronic Storage Refinance - - Proposals Not Closing Disclosure Adopted - Purchase – Buyer - Purchase - Seller Resources Takeaways What Lies Ahead? Q&A © Copyright Stewart 2014 8
  9. 9. About the CFPB 2007 Today’s Topics - About the CFPB 2008 2009 2010 2011 2012 2013 -History of Disclosures Effective Date About the CFPB - Loan Estimate Mortgage Rules - Closing Disclosure - Service Providers - Delivery Alternatives - QM / ATR - - Three-DayDisclosures Rule Integrated -Final Rule All-In APR -Loan Estimate Electronic Storage Refinance - - Proposals Not Closing Disclosure Adopted - Purchase – Buyer - Purchase - Seller Resources Takeaways What Lies Ahead? Q&A CFPB formed with Richard Cordray as Director Supervisory authority over Banks and Non-Banks. Enforcement authority over RESPA and TILA - © Copyright Stewart 2014 9
  10. 10. The CFPB Timeline Today’s Topics - About the CFPB 2007 2008 2009 2010 2011 2012 2013 -History of Disclosures Effective Date About the CFPB - Loan Estimate Mortgage Rules - Closing Disclosure - Service Providers - Delivery Alternatives Proposed and finalized many rules in 2012 - QM / ATR - - Three-DayDisclosures Rule Integrated -Final Rule All-In APR -Loan Estimate Electronic Storage Refinance - - Proposals Not Closing Disclosure Adopted - Purchase – Buyer - Purchase - Seller Resources Takeaways What Lies Ahead? Q&A © Copyright Stewart 2014 10
  11. 11. The CFPB Timeline Today’s Topics - About the CFPB 2007 2008 2009 2010 2011 2012 2013 -History of Disclosures Effective Date About the CFPB - Loan Estimate Mortgage Rules - Closing Disclosure - Service Providers Released the Final Rule on Integrated Disclosures November 20, 2013 at the CFPB Field Hearing in Boston as part of the “Know Before You Owe” initiative. - Delivery Alternatives - QM / ATR - - Three-DayDisclosures Rule Integrated -Final Rule All-In APR -Loan Estimate Electronic Storage Refinance - - Proposals Not Closing Disclosure Adopted - Purchase – Buyer - Purchase - Seller Resources Takeaways What Lies Ahead? Q&A Stewart’s policy analyst talks with CFPB Director, Richard Cordray about Stewart’s effort to provide education on the new disclosures. © Copyright Stewart 2014 11
  12. 12. CFPB Continues to Remedy Historic Closing Problems Today’s Topics - About the CFPB -History of Disclosures Effective Date About the CFPB - Loan Estimate Mortgage Rules Have you ever experienced one or more of the following? - Closing Disclosure - Service Providers - Delivery Alternatives - QM / ATR - - Three-DayDisclosures Rule Integrated -Final Rule All-In APR -Loan Estimate Electronic Storage Refinance - - Proposals Not Closing Disclosure Adopted - Purchase – Buyer Buyer and real estate professional have arrived at the title company for closing Buyer has no idea how much money they are responsible to bring - Purchase - Seller Resources Takeaways What Lies Ahead? Q&A Real estate professional is frustrated they have yet to receive a copy of the HUD-1 Loan officer is saying the title company is responsible for the delay Title company is saying they just received the loan package When the consumer wins… we all win! © Copyright Stewart 2014 12
  13. 13. Preview of things to come in 2014 Today’s Topics - About the CFPB -History of Disclosures Effective Date About the CFPB - Loan Estimate Mortgage Rules - Closing Disclosure - Service Providers - Delivery Alternatives - QM / ATR CFPB Director Richard Cordray Boston Field Hearing, November 20, 2013 - - Three-DayDisclosures Rule Integrated -Final Rule All-In APR -Loan Estimate Electronic Storage Refinance - - Proposals Not Closing Disclosure Adopted - Purchase – Buyer - Purchase - Seller Resources Takeaways What Lies Ahead? Q&A “So as part of our “Know Before You Owe” initiative, we are making a commitment to work with industry to improve the mortgage closing experience for consumers through technology. We believe that “eClosings” could represent a positive development along these lines, and we want to know more about how we can foster innovation in this area. © Copyright Stewart 2014 13
  14. 14. Mortgage Rules Today’s Topics - About the CFPB -History of Disclosures Effective Date About the CFPB - Loan Estimate Mortgage Rules - Closing Disclosure - Service Providers - Delivery Alternatives - QM / ATR - - Three-DayDisclosures Rule Integrated -Final Rule All-In APR -Loan Estimate Electronic Storage Refinance - - Proposals Not Closing Disclosure Adopted - Purchase – Buyer - Purchase - Seller Resources Takeaways Service Providers What Lies Ahead? Q&A Qualified Mortgages Integrated Disclosures © Copyright Stewart 2014 14
  15. 15. Service Provider “flight to quality” Today’s Topics - About the CFPB -History of Disclosures Effective Date About the CFPB - Loan Estimate Mortgage Rules - Closing Disclosure - Service Providers - Delivery Alternatives - QM / ATR CFPB Bulletin to Banks and Non-Banks stating they must use quality service providers. - - Three-DayDisclosures Rule Integrated -Final Rule All-In APR -Loan Estimate Electronic Storage Refinance - - Proposals Not Closing Disclosure Adopted - Purchase – Buyer - Purchase - Seller Resources Takeaways What Lies Ahead? Q&A © Copyright Stewart 2014 15
  16. 16. Qualified Mortgage / Ability-to-Repay Today’s Topics - About the CFPB -History of Disclosures Effective Date About the CFPB - Loan Estimate Mortgage Rules - Closing Disclosure - Service Providers - Delivery Alternatives - QM / ATR - - Three-DayDisclosures Rule Integrated -Final Rule All-In APR -Loan Estimate Electronic Storage Refinance - - Proposals Not Closing Disclosure Adopted - Purchase – Buyer - Purchase - Seller Resources Takeaways What Lies Ahead? Q&A © Copyright Stewart 2014 16
  17. 17. CFPB Finalizes Rule on Integrated Disclosures Today’s Topics - About the CFPB -History of Disclosures Effective Date About the CFPB - Loan Estimate Mortgage Rules - Closing Disclosure - Service Providers - Delivery Alternatives - QM / ATR - - Three-DayDisclosures Rule Integrated -Final Rule All-In APR -Loan Estimate Electronic Storage Refinance - - Proposals Not Closing Disclosure Adopted - Purchase – Buyer - Purchase - Seller Resources Takeaways Better Disclosures What Lies Ahead? Q&A © Copyright Stewart 2014 17
  18. 18. Detailed Summary of the Final Rule Today’s Topics - About the CFPB -History of Disclosures Effective Date About the CFPB - Loan Estimate Mortgage Rules - Closing Disclosure Detailed Summary – 7 pages - Service Providers Scope - Delivery Alternatives - QM / ATR - - Three-DayDisclosures Rule Integrated Loan Estimate -Final Rule All-In APR -Loan Estimate Electronic Storage Closing Disclosure Refinance - - Proposals Not Closing Disclosure Adopted - Purchase – Buyer Limits on Cost Increases - Purchase - Seller Resources Proposals Not Adopted Takeaways What Lies Ahead? Effective Date Q&A *Final Rule – 1,888 pages © Copyright Stewart 2014 18
  19. 19. Detailed Summary of the Final Rule Today’s Topics - About the CFPB -History of Disclosures Effective Date 1 Scope a) b) c) d) Applications on or after 8/1/2015 fall under new rules Closed-end loans only - No home equity lines No reverse mortgages No mobile home loans Loan Estimate a) b) c) d) e) Replaces Good Faith Est. / Early Truth-in-Lending Mortgage Broker may provide / Lender is still responsible Delivery must be within 3 Business Days of ‘application’ Limitation on up-front fees with exception for credit reports Disclaimer on early estimates used before Loan Estimate Closing Disclosure a) b) c) d) Replaces HUD-1 and Final Truth-in-Lending Consumer must receive at least 3 business days before signing APR changes over 1/8% require re-disclosure/ 3 Bus. Day wait Escrow may prepare and/or deliver* Limits on Increases a) Items that generally cannot increase: a) Creditor’s or broker’s charges for its own services b) Charges for services provided by an affiliate c) Charges where consumer is not permitted to shop b) Other services can generally increase by 10% or less Exceptions a) b) c) d) Not Adopted a) Re-defined “All In” APR b) Storage in standard, electronic machine-readable format c) Disclosure of Approximate Cost of Funds About the CFPB - Loan Estimate Mortgage Rules - Closing Disclosure - Service Providers - Delivery Alternatives - QM / ATR - - Three-DayDisclosures Rule Integrated -Final Rule All-In APR 2 -Loan Estimate Electronic Storage Refinance - - Proposals Not Closing Disclosure Adopted - Purchase – Buyer - Purchase - Seller 3 Resources Takeaways What Lies Ahead? Q&A 4 4a 5 Consumer requests the change Consumer chooses their own service provider Information at application is/becomes inaccurate Loan Estimate expires © Copyright Stewart 2014 19
  20. 20. CFPB Goals in Redesigning Forms Today’s Topics - About the CFPB Help consumers by making all forms look similar -History of Disclosures Effective Date About the CFPB - Loan Estimate Help consumers shop for best loan Mortgage Rules - Closing Disclosure - Service Providers - Delivery Alternatives Help consumers guard against hikes in charges at closing - QM / ATR - - Three-DayDisclosures Rule Integrated -Final Rule All-In APR -Loan Estimate Electronic Storage Refinance - - Proposals Not Help consumers understand future obligations Good Faith Estimate Truth in Lending HUD-1 Closing Disclosure Adopted - Purchase – Buyer - Purchase - Seller Resources Takeaways What Lies Ahead? Q&A © Copyright Stewart 2014 20
  21. 21. Introducing the Forms Today’s Topics - About the CFPB -History of Disclosures Effective Date About the CFPB - Loan Estimate Mortgage Rules Today’s look at the samples provided by the Bureau in the final rule announced November 20, 2013. - Closing Disclosure - Service Providers - Delivery Alternatives - QM / ATR - - Three-DayDisclosures Rule Integrated -Final Rule All-In APR -Loan Estimate Electronic Storage Refinance - - Proposals Not Closing Disclosure Adopted - Purchase – Buyer - Purchase - Seller Resources Takeaways What Lies Ahead? Q&A © Copyright Stewart 2014 21
  22. 22. How important are the new disclosures?? Today’s Topics - About the CFPB -History of Disclosures Effective Date About the CFPB - Loan Estimate Mortgage Rules - Closing Disclosure - Service Providers - Delivery Alternatives - QM / ATR - - Three-DayDisclosures Rule Integrated -Final Rule All-In APR -Loan Estimate Electronic Storage Refinance - - Proposals Not Closing Disclosure Adopted - Purchase – Buyer - Purchase - Seller Resources Takeaways What Lies Ahead? Q&A © Copyright Stewart 2014 22
  23. 23. Closing Disclosure for Purchase – Page 1 Closing Information Today’s Topics - About the CFPB -History of Disclosures Effective Date Transaction Information About the CFPB - Loan Estimate Mortgage Rules Loan Information - Closing Disclosure - Service Providers - Delivery Alternatives - QM / ATR Loan Terms - - Three-DayDisclosures Rule Integrated -Final Rule All-In APR Projected Payments -Loan Estimate Electronic Storage Refinance - - Proposals Not Costs at Closing Closing Disclosure Adopted - Purchase – Buyer - Purchase - Seller Resources Takeaways What Lies Ahead? Q&A © Copyright Stewart 2014 23
  24. 24. Closing Disclosure for Purchase – Page 1 - Detail Today’s Topics - About the CFPB -History of Disclosures Effective Date About the CFPB - Loan Estimate Mortgage Rules - Closing Disclosure - Service Providers - Delivery Alternatives - QM / ATR - - Three-DayDisclosures Rule Integrated -Final Rule All-In APR -Loan Estimate Electronic Storage Refinance - - Proposals Not Closing Disclosure Adopted - Purchase – Buyer - Purchase - Seller Resources Takeaways What Lies Ahead? Q&A © Copyright Stewart 2014 24
  25. 25. Closing Disclosure for Purchase – Page 1 - Detail Today’s Topics - About the CFPB -History of Disclosures Effective Date About the CFPB - Loan Estimate Mortgage Rules - Closing Disclosure - Service Providers - Delivery Alternatives - QM / ATR - - Three-DayDisclosures Rule Integrated -Final Rule All-In APR -Loan Estimate Electronic Storage Refinance - - Proposals Not Closing Disclosure Adopted - Purchase – Buyer - Purchase - Seller Resources Takeaways What Lies Ahead? Q&A © Copyright Stewart 2014 25
  26. 26. Closing Disclosure for Purchase – Page 2 Loan Costs Today’s Topics - About the CFPB -History of Disclosures Effective Date Other Costs About the CFPB - Loan Estimate Mortgage Rules Total Costs - Closing Disclosure - Service Providers - Delivery Alternatives - QM / ATR - - Three-DayDisclosures Rule Integrated -Final Rule All-In APR -Loan Estimate Electronic Storage Refinance - - Proposals Not Closing Disclosure Adopted - Purchase – Buyer - Purchase - Seller Resources Takeaways What Lies Ahead? Q&A © Copyright Stewart 2014 26
  27. 27. Closing Disclosure for Purchase – Page 2 - Detail Today’s Topics - About the CFPB -History of Disclosures Effective Date About the CFPB - Loan Estimate Mortgage Rules - Closing Disclosure - Service Providers - Delivery Alternatives - QM / ATR - - Three-DayDisclosures Rule Integrated -Final Rule All-In APR -Loan Estimate Electronic Storage Refinance - - Proposals Not Closing Disclosure Adopted - Purchase – Buyer - Purchase - Seller Resources Takeaways What Lies Ahead? Q&A © Copyright Stewart 2014 27
  28. 28. Closing Disclosure for Purchase – Page 2 - Detail Today’s Topics - About the CFPB -History of Disclosures Effective Date About the CFPB - Loan Estimate Mortgage Rules - Closing Disclosure - Service Providers - Delivery Alternatives - QM / ATR - - Three-DayDisclosures Rule Integrated -Final Rule All-In APR -Loan Estimate Electronic Storage Refinance - - Proposals Not Closing Disclosure Adopted - Purchase – Buyer - Purchase - Seller Resources Takeaways What Lies Ahead? Q&A © Copyright Stewart 2014 28
  29. 29. Closing Disclosure for Purchase – Page 3 Cash-to-Close Calculations Today’s Topics - About the CFPB -History of Disclosures Effective Date Transaction Summaries About the CFPB - Loan Estimate Mortgage Rules - Closing Disclosure - Service Providers - Delivery Alternatives - QM / ATR - - Three-DayDisclosures Rule Integrated -Final Rule All-In APR -Loan Estimate Electronic Storage Refinance - - Proposals Not Closing Disclosure Adopted - Purchase – Buyer - Purchase - Seller Resources Takeaways What Lies Ahead? Q&A © Copyright Stewart 2014 29
  30. 30. Closing Disclosure for Purchase – Page 3 - Detail Today’s Topics - About the CFPB -History of Disclosures Effective Date About the CFPB - Loan Estimate Mortgage Rules - Closing Disclosure - Service Providers - Delivery Alternatives - QM / ATR - - Three-DayDisclosures Rule Integrated -Final Rule All-In APR -Loan Estimate Electronic Storage Refinance - - Proposals Not Closing Disclosure Adopted - Purchase – Buyer - Purchase - Seller Resources Takeaways What Lies Ahead? Q&A © Copyright Stewart 2014 30
  31. 31. Closing Disclosure for Purchase – Page 3 - Detail Today’s Topics - About the CFPB -History of Disclosures Effective Date About the CFPB - Loan Estimate Mortgage Rules - Closing Disclosure - Service Providers - Delivery Alternatives - QM / ATR - - Three-DayDisclosures Rule Integrated -Final Rule All-In APR -Loan Estimate Electronic Storage Refinance - - Proposals Not Closing Disclosure Adopted - Purchase – Buyer - Purchase - Seller Resources Takeaways What Lies Ahead? Q&A © Copyright Stewart 2014 31
  32. 32. Closing Disclosure for Purchase – Page 4 Loan Disclosures Today’s Topics - About the CFPB -History of Disclosures Effective Date Escrow Account About the CFPB - Loan Estimate Mortgage Rules - Closing Disclosure - Service Providers - Delivery Alternatives - QM / ATR - - Three-DayDisclosures Rule Integrated -Final Rule All-In APR -Loan Estimate Electronic Storage Refinance - - Proposals Not Closing Disclosure Adopted - Purchase – Buyer - Purchase - Seller Resources Takeaways What Lies Ahead? Q&A © Copyright Stewart 2014 32
  33. 33. Closing Disclosure for Purchase – Page 4 - Detail Today’s Topics - About the CFPB -History of Disclosures Effective Date About the CFPB - Loan Estimate Mortgage Rules - Closing Disclosure - Service Providers - Delivery Alternatives - QM / ATR - - Three-DayDisclosures Rule Integrated -Final Rule All-In APR -Loan Estimate Electronic Storage Refinance - - Proposals Not Closing Disclosure Adopted - Purchase – Buyer - Purchase - Seller Resources Takeaways What Lies Ahead? Q&A © Copyright Stewart 2014 33
  34. 34. Closing Disclosure for Purchase – Page 5 Loan Calculations Today’s Topics - About the CFPB -History of Disclosures Effective Date Other Disclosures About the CFPB - Loan Estimate Mortgage Rules Questions - Closing Disclosure - Service Providers - Delivery Alternatives - QM / ATR Contact Information - - Three-DayDisclosures Rule Integrated -Final Rule All-In APR Confirmation of Receipt -Loan Estimate Electronic Storage Refinance - - Proposals Not Closing Disclosure Adopted - Purchase – Buyer - Purchase - Seller Resources Takeaways What Lies Ahead? Q&A © Copyright Stewart 2014 34
  35. 35. Closing Disclosure for Purchase – Page 5 Today’s Topics - About the CFPB -History of Disclosures Effective Date About the CFPB - Loan Estimate Mortgage Rules - Closing Disclosure - Service Providers - Delivery Alternatives - QM / ATR - - Three-DayDisclosures Rule Integrated -Final Rule All-In APR -Loan Estimate Electronic Storage Refinance - - Proposals Not Closing Disclosure Adopted - Purchase – Buyer - Purchase - Seller Resources Takeaways What Lies Ahead? Q&A © Copyright Stewart 2014 35
  36. 36. Closing Disclosure for Purchase – Page 5 Today’s Topics - About the CFPB -History of Disclosures Effective Date About the CFPB - Loan Estimate Mortgage Rules - Closing Disclosure - Service Providers - Delivery Alternatives - QM / ATR - - Three-DayDisclosures Rule Integrated -Final Rule All-In APR -Loan Estimate Electronic Storage Refinance - - Proposals Not Closing Disclosure Adopted - Purchase – Buyer - Purchase - Seller Resources Takeaways What Lies Ahead? Q&A © Copyright Stewart 2014 36
  37. 37. Closing Disclosure for Seller Only – Page 1 Closing Information Today’s Topics - About the CFPB -History of Disclosures Effective Date Transaction Information About the CFPB - Loan Estimate Mortgage Rules Summaries of Transactions - Closing Disclosure - Service Providers - Delivery Alternatives - QM / ATR Contact Information - - Three-DayDisclosures Rule Integrated -Final Rule All-In APR -Loan Estimate Electronic Storage Refinance - - Proposals Not Closing Disclosure Adopted - Purchase – Buyer - Purchase - Seller Resources Takeaways What Lies Ahead? Q&A © Copyright Stewart 2014 37
  38. 38. Closing Disclosure for Seller Only – Page 1 - Detail Today’s Topics - About the CFPB -History of Disclosures Effective Date About the CFPB - Loan Estimate Mortgage Rules - Closing Disclosure - Service Providers - Delivery Alternatives - QM / ATR - - Three-DayDisclosures Rule Integrated -Final Rule All-In APR -Loan Estimate Electronic Storage Refinance - - Proposals Not Closing Disclosure Adopted - Purchase – Buyer - Purchase - Seller Resources Takeaways What Lies Ahead? Q&A © Copyright Stewart 2014 38
  39. 39. Closing Disclosure for Seller Only – Page 1 - Detail Today’s Topics - About the CFPB -History of Disclosures Effective Date About the CFPB - Loan Estimate Mortgage Rules - Closing Disclosure - Service Providers - Delivery Alternatives - QM / ATR - - Three-DayDisclosures Rule Integrated -Final Rule All-In APR -Loan Estimate Electronic Storage Refinance - - Proposals Not Closing Disclosure Adopted - Purchase – Buyer - Purchase - Seller Resources Takeaways What Lies Ahead? Q&A © Copyright Stewart 2014 39
  40. 40. Closing Disclosure for Seller Only – Page 2 Closing Cost Details Today’s Topics - About the CFPB -History of Disclosures Effective Date Loan Costs About the CFPB - Loan Estimate Mortgage Rules Other Costs - Closing Disclosure - Service Providers - Delivery Alternatives - QM / ATR - - Three-DayDisclosures Rule Integrated -Final Rule All-In APR -Loan Estimate Electronic Storage Refinance - - Proposals Not Closing Disclosure Adopted - Purchase – Buyer - Purchase - Seller Resources Takeaways What Lies Ahead? Q&A © Copyright Stewart 2014 40
  41. 41. Closing Disclosure for Seller Only – Page 2 - Detail Today’s Topics - About the CFPB -History of Disclosures Effective Date About the CFPB - Loan Estimate Mortgage Rules - Closing Disclosure - Service Providers - Delivery Alternatives - QM / ATR - - Three-DayDisclosures Rule Integrated -Final Rule All-In APR -Loan Estimate Electronic Storage Refinance - - Proposals Not Closing Disclosure Adopted - Purchase – Buyer - Purchase - Seller Resources Takeaways What Lies Ahead? Q&A © Copyright Stewart 2014 41
  42. 42. Closing Disclosure for Seller Only – Page 2 - Detail Today’s Topics - About the CFPB -History of Disclosures Effective Date About the CFPB - Loan Estimate Mortgage Rules - Closing Disclosure - Service Providers - Delivery Alternatives - QM / ATR - - Three-DayDisclosures Rule Integrated -Final Rule All-In APR -Loan Estimate Electronic Storage Refinance - - Proposals Not Closing Disclosure Adopted - Purchase – Buyer - Purchase - Seller Resources Takeaways What Lies Ahead? Q&A © Copyright Stewart 2014 42
  43. 43. Resources Today’s Topics - About the CFPB -History of Disclosures Effective Date About the CFPB - Loan Estimate Mortgage Rules stewart.com/cfpb Service Provider Memo - Closing Disclosure - Service Providers - Delivery Alternatives - QM / ATR - - Three-DayDisclosures Rule Integrated -Final Rule All-In APR -Loan Estimate Electronic Storage Refinance - - Proposals Not Closing Disclosure Adopted - Purchase – Buyer - Purchase - Seller Resources Takeaways What Lies Ahead? Q&A ALTA Best Practices QM / ATR Integrated Disclosures Loan Estimate Closing Disclosure Realtor info Lender info Homebuyer education © Copyright Stewart 2014 43
  44. 44. Takeaways Today’s Topics - About the CFPB -History of Disclosures Effective Date About the CFPB - Loan Estimate Mortgage Rules - Closing Disclosure - Service Providers - Delivery Alternatives - QM / ATR - - Three-DayDisclosures Rule Integrated -Final Rule All-In APR -Loan Estimate Electronic Storage Refinance - - Proposals Not Closing Disclosure Adopted - Purchase – Buyer - Purchase - Seller Resources Takeaways What Lies Ahead? Q&A Be Proactive Discuss the issues Identify process changes Plan for the 3-Day Rule Print the new forms from stewart.com/cfpb Practice with your team Invite your compliance officer to join us Partner with Stewart © Copyright Stewart 2014 44
  45. 45. What lies ahead? Today’s Topics - About the CFPB -History of Disclosures Effective Date About the CFPB - Loan Estimate Mortgage Rules - Closing Disclosure - Service Providers - Delivery Alternatives - QM / ATR - - Three-DayDisclosures Rule Integrated -Final Rule All-In APR -Loan Estimate Electronic Storage Refinance - - Proposals Not Closing Disclosure Adopted - Purchase – Buyer - Purchase - Seller Resources Takeaways What Lies Ahead? Q&A © Copyright Stewart 2014 45
  46. 46. Questions? Today’s Topics - About the CFPB -History of Disclosures Effective Date About the CFPB - Loan Estimate Mortgage Rules - Closing Disclosure - Service Providers - Delivery Alternatives - QM / ATR - - Three-DayDisclosures Rule Integrated -Final Rule All-In APR -Loan Estimate Electronic Storage Refinance - - Proposals Not Closing Disclosure Adopted - Purchase – Buyer - Purchase - Seller Resources Takeaways What Lies Ahead? Q&A Q&A © Copyright Stewart 2014 46
  47. 47. Today’s Topics - About the CFPB -History of Disclosures Effective Date About the CFPB - Loan Estimate Mortgage Rules - Closing Disclosure - Service Providers - Delivery Alternatives - QM / ATR - - Three-DayDisclosures Rule Integrated -Final Rule All-In APR -Loan Estimate Electronic Storage Refinance - - Proposals Not Closing Disclosure Adopted - Purchase – Buyer - Purchase - Seller Resources Takeaways What Lies Ahead? Q&A Thank You! © Copyright Stewart 2014 47

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