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TILA RESPA Integration disclosure 
timeline example 
September 2014
Disclaimer 
This document does not represent legal interpretation, guidance or 
advice of the Bureau. While efforts have been made to ensure 
accuracy, this presentation is not a substitute for the rule. Only the 
rule and its Official Interpretations can provide complete and 
definitive information regarding requirements. This document does 
not bind the Bureau and does not create any rights, benefits, or 
defenses, substantive or procedural, that are enforceable by any party 
in any manner. 
2
General information 
The pages that follow illustrate, in calendar form, the process and 
timing of disclosures for an example real estate purchase transaction 
under the TILA RESPA Integrated Disclosure rule that will become 
effective on August 1, 2015. 
For the purposes of this example, we have made the following 
assumptions: 
 The Creditor is not open for business on Saturdays. 
 The property is located in a State where consummation is the day of 
closing, or signing of documents, between the Consumer and Seller. 
 All parties are targeting a closing date of October 29. 
 The Consumer’s application is received by the Creditor on Monday, 
August 3, 2015. 
3
General information continued 
Days with bold borders signal either triggers for requirements or 
satisfaction of disclosure obligations. 
The calendar is not intended to show all of the events that can occur 
during the course of a real estate sales transaction. Only examples of 
events that could have an impact on disclosures are described. There 
may be other events that have an effect on the timing and 
responsibilities of the Creditor concerning the disclosures. In some 
instances, the events that are described in this calendar may not have 
an effect on the timing and responsibilities of the Creditor. For more 
complete information, please see Regulation Z § 1026.19(e) and (f) and 
its commentary, which contain additional examples. 
4
Definitions 
 Contract refers to the real estate purchase contract between the 
Consumer and Seller. 
 Application is defined in Regulation Z § 1026.2(a)(3). 
 LLPA is a loan level pricing adjustment or any other secondary 
market risk-based pricing mechanism. 
 Issue means to deliver or place in the mail the applicable disclosure 
discussed in the example. 
5
Definitions continued 
 For purposes of providing the Loan Estimate, or any revised Loan 
Estimate, a business day is a day on which the creditor’s offices are 
open to the public for carrying out substantially all of its business 
functions. 
 For all other purposes, business day means all calendar days except 
Sundays and legal public holidays specified in 5 U.S.C. 6103(a) such 
as, New Year’s Day, the Birthday of Martin Luther King, Jr., 
Washington’s Birthday, Memorial Day, Independence Day, Labor 
Day, Columbus Day, Veterans Day, Thanksgiving Day, and 
Christmas Day. 
6
List of events 
This timeline shows the effect of the following events during the course 
of the origination of the loan: 
 Receipt of an addendum to Contract modifying the allocation of 
transfer taxes between the Consumer and Seller. (August 28th) 
 Appraisal provides a property value resulting in a loan-to-value 
ratio higher than 80%, triggering mortgage insurance. (September 
4th) 
 An updated credit report obtained by the Creditor shows a changed 
credit score, triggering a LLPA. (September 22nd) 
7
List of events continued 
 A rate lock is requested by the Consumer. (October 5th) 
 The Consumer decides to obtain an Owner’s Title Policy the week 
prior to consummation. (October 21st) 
 During a walkthrough two days before consummation, a broken 
dishwasher is discovered. (October 27th) 
 The recording fees collected were $100 more than needed when the 
documents are presented for recording after consummation. 
(October 30th) 
8
August 2015 
Sun Mon Tue Wed Thu Fri Sat 
1 
2 3 4 5 6 7 8 
9 10 11 12 13 14 15 
16 17 18 19 20 21 22 
23 24 25 26 27 28 29 
30 31 
Application received by 
Creditor. Loan Estimate delivered 
or placed in mail. 
Creditor may request veri-fying 
information. 
The only fee Creditor may 
collect before providing 
the Loan Estimate is for 
the credit report. 
Consumer receives 
Loan Estimate. 
Consumer indicates an 
intention to proceed with 
Application. 
Appraisal ordered by 
Creditor. 
Title Insurance ordered 
by Real Estate Agent. 
Receipt of Addendum by 
Creditor to Contract modify-ing 
allocation of transfer 
taxes between Consumer 
and Seller. Revised Loan 
Estimate permitted. 
Copy of Contract re-ceived 
by Creditor. 
7-day waiting period for 
consummation after deliv-ery 
of Loan Estimate ex-pired. 
First day when 
consummation can occur.
September 2015 
Sun Mon Tue Wed Thu Fri Sat 
1 2 3 4 5 
6 7 8 9 10 11 12 
13 14 15 16 17 18 19 
20 21 22 23 24 25 26 
27 28 29 30 
Last day for creditor to 
issue revised Loan Esti-mate 
for allocation of 
transfer taxes on Adden-dum 
to Contract. 
Appraisal received by 
Creditor. LTV now ex-ceeds 
80%. 
Revised Loan Estimate 
permitted. 
HOLIDAY— LABOR DAY 
Last day for Creditor to 
issue revised Loan Esti-mate 
to add mortgage 
insurance coverage, etc., 
due to changed circum-stance 
of LTV exceeding 
80%. 
Updated credit report ob-tained 
showing a changed 
credit score. LLPA trig-gered. 
Revised Loan Estimate 
permitted. 
Last day for Creditor to 
issue revised Loan Esti-mate 
for addition of any 
charge or any other 
change to terms of loan 
due to change in credit 
score.
October 2015 
Sun Mon Tue Wed Thu Fri Sat 
1 2 3 
4 5 6 7 8 9 10 
11 12 13 14 15 16 17 
18 19 20 21 22 23 24 
25 26 27 28 29 30 31 
CLOSING DATE 
Revised Closing Disclo-sure 
reflecting seller cred-it 
for broken dishwasher 
provided to Consumer 
and Seller. 
Inspection contingency of 
Contract is removed by 
the Consumer. 
Rate lock requested by 
Consumer. 
Rate lock agreement exe-cuted 
by Creditor. 
Creditor is required to deliv-er 
or place in the mail the 
revised Loan Estimate the 
same day the interest rate 
is locked. 
Consumer must receive 
Closing Disclosure. 
If delivering Closing Dis-closure 
by mail, Creditor 
must place Closing Dis-closure 
in mail on this 
date. Closing Disclosure 
must reflect information 
provided by Consumer on 
10/21. 
Consumer informs Creditor 
of intent to purchase an 
enhanced owner’s title in-surance 
policy. 
Creditor sends Closing 
Disclosure by overnight 
delivery. 
Consumer receives and 
signs for the overnight 
delivery of the Closing 
Disclosure. Earliest clos-ing 
date is 10/28. 
Walkthrough shows dish-washer 
is broken. 
Seller credit for broken 
dishwasher provided in 
Addendum to Contract. 
Creditor required to permit 
inspection of Closing Dis-closure 
by Consumer on 
this day. 
Recording office indi-cates 
transfer taxes paid 
by Consumer overpaid 
by $100 and refunds 
amount to Consumer.
November 2015 
Sun Mon Tue Wed Thu Fri Sat 
1 2 3 4 5 6 7 
8 9 10 11 12 13 14 
15 16 17 18 19 20 21 
22 23 24 25 26 27 28 
29 30 
Last day for Creditor to 
deliver or place in mail 
corrected Closing Disclo-sure 
showing decrease in 
transfer taxes paid by 
Consumer.
December 2015 
Sun Mon Tue Wed Thu Fri Sat 
1 2 3 4 5 
6 7 8 9 10 11 12 
13 14 15 16 17 18 19 
20 21 22 23 24 25 26 
27 28 29 30 31 
Last day for Creditor to 
provide refund to Con-sumer 
and to deliver or 
place in the mail a correct-ed 
Closing Disclosure re-flecting 
the refund. 
Last day for Creditor to 
mail refund of any toler-ance 
cure. (Note: other 
delivery methods can be 
used so long as the re-fund 
is received no later 
than the 60th day after 
consummation).
Additional resources 
You can find additional tools and information on regulatory 
implementation at 
http://www.consumerfinance.gov/regulatory-implementation/. 
If you have improvements or suggestions, please let us know at 
CFPB_MortgageRulesImplementation@cfpb.gov

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TILA RESPA Integration Disclosure Timeline Example

  • 1. TILA RESPA Integration disclosure timeline example September 2014
  • 2. Disclaimer This document does not represent legal interpretation, guidance or advice of the Bureau. While efforts have been made to ensure accuracy, this presentation is not a substitute for the rule. Only the rule and its Official Interpretations can provide complete and definitive information regarding requirements. This document does not bind the Bureau and does not create any rights, benefits, or defenses, substantive or procedural, that are enforceable by any party in any manner. 2
  • 3. General information The pages that follow illustrate, in calendar form, the process and timing of disclosures for an example real estate purchase transaction under the TILA RESPA Integrated Disclosure rule that will become effective on August 1, 2015. For the purposes of this example, we have made the following assumptions:  The Creditor is not open for business on Saturdays.  The property is located in a State where consummation is the day of closing, or signing of documents, between the Consumer and Seller.  All parties are targeting a closing date of October 29.  The Consumer’s application is received by the Creditor on Monday, August 3, 2015. 3
  • 4. General information continued Days with bold borders signal either triggers for requirements or satisfaction of disclosure obligations. The calendar is not intended to show all of the events that can occur during the course of a real estate sales transaction. Only examples of events that could have an impact on disclosures are described. There may be other events that have an effect on the timing and responsibilities of the Creditor concerning the disclosures. In some instances, the events that are described in this calendar may not have an effect on the timing and responsibilities of the Creditor. For more complete information, please see Regulation Z § 1026.19(e) and (f) and its commentary, which contain additional examples. 4
  • 5. Definitions  Contract refers to the real estate purchase contract between the Consumer and Seller.  Application is defined in Regulation Z § 1026.2(a)(3).  LLPA is a loan level pricing adjustment or any other secondary market risk-based pricing mechanism.  Issue means to deliver or place in the mail the applicable disclosure discussed in the example. 5
  • 6. Definitions continued  For purposes of providing the Loan Estimate, or any revised Loan Estimate, a business day is a day on which the creditor’s offices are open to the public for carrying out substantially all of its business functions.  For all other purposes, business day means all calendar days except Sundays and legal public holidays specified in 5 U.S.C. 6103(a) such as, New Year’s Day, the Birthday of Martin Luther King, Jr., Washington’s Birthday, Memorial Day, Independence Day, Labor Day, Columbus Day, Veterans Day, Thanksgiving Day, and Christmas Day. 6
  • 7. List of events This timeline shows the effect of the following events during the course of the origination of the loan:  Receipt of an addendum to Contract modifying the allocation of transfer taxes between the Consumer and Seller. (August 28th)  Appraisal provides a property value resulting in a loan-to-value ratio higher than 80%, triggering mortgage insurance. (September 4th)  An updated credit report obtained by the Creditor shows a changed credit score, triggering a LLPA. (September 22nd) 7
  • 8. List of events continued  A rate lock is requested by the Consumer. (October 5th)  The Consumer decides to obtain an Owner’s Title Policy the week prior to consummation. (October 21st)  During a walkthrough two days before consummation, a broken dishwasher is discovered. (October 27th)  The recording fees collected were $100 more than needed when the documents are presented for recording after consummation. (October 30th) 8
  • 9. August 2015 Sun Mon Tue Wed Thu Fri Sat 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 Application received by Creditor. Loan Estimate delivered or placed in mail. Creditor may request veri-fying information. The only fee Creditor may collect before providing the Loan Estimate is for the credit report. Consumer receives Loan Estimate. Consumer indicates an intention to proceed with Application. Appraisal ordered by Creditor. Title Insurance ordered by Real Estate Agent. Receipt of Addendum by Creditor to Contract modify-ing allocation of transfer taxes between Consumer and Seller. Revised Loan Estimate permitted. Copy of Contract re-ceived by Creditor. 7-day waiting period for consummation after deliv-ery of Loan Estimate ex-pired. First day when consummation can occur.
  • 10. September 2015 Sun Mon Tue Wed Thu Fri Sat 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 Last day for creditor to issue revised Loan Esti-mate for allocation of transfer taxes on Adden-dum to Contract. Appraisal received by Creditor. LTV now ex-ceeds 80%. Revised Loan Estimate permitted. HOLIDAY— LABOR DAY Last day for Creditor to issue revised Loan Esti-mate to add mortgage insurance coverage, etc., due to changed circum-stance of LTV exceeding 80%. Updated credit report ob-tained showing a changed credit score. LLPA trig-gered. Revised Loan Estimate permitted. Last day for Creditor to issue revised Loan Esti-mate for addition of any charge or any other change to terms of loan due to change in credit score.
  • 11. October 2015 Sun Mon Tue Wed Thu Fri Sat 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 CLOSING DATE Revised Closing Disclo-sure reflecting seller cred-it for broken dishwasher provided to Consumer and Seller. Inspection contingency of Contract is removed by the Consumer. Rate lock requested by Consumer. Rate lock agreement exe-cuted by Creditor. Creditor is required to deliv-er or place in the mail the revised Loan Estimate the same day the interest rate is locked. Consumer must receive Closing Disclosure. If delivering Closing Dis-closure by mail, Creditor must place Closing Dis-closure in mail on this date. Closing Disclosure must reflect information provided by Consumer on 10/21. Consumer informs Creditor of intent to purchase an enhanced owner’s title in-surance policy. Creditor sends Closing Disclosure by overnight delivery. Consumer receives and signs for the overnight delivery of the Closing Disclosure. Earliest clos-ing date is 10/28. Walkthrough shows dish-washer is broken. Seller credit for broken dishwasher provided in Addendum to Contract. Creditor required to permit inspection of Closing Dis-closure by Consumer on this day. Recording office indi-cates transfer taxes paid by Consumer overpaid by $100 and refunds amount to Consumer.
  • 12. November 2015 Sun Mon Tue Wed Thu Fri Sat 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 Last day for Creditor to deliver or place in mail corrected Closing Disclo-sure showing decrease in transfer taxes paid by Consumer.
  • 13. December 2015 Sun Mon Tue Wed Thu Fri Sat 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 Last day for Creditor to provide refund to Con-sumer and to deliver or place in the mail a correct-ed Closing Disclosure re-flecting the refund. Last day for Creditor to mail refund of any toler-ance cure. (Note: other delivery methods can be used so long as the re-fund is received no later than the 60th day after consummation).
  • 14. Additional resources You can find additional tools and information on regulatory implementation at http://www.consumerfinance.gov/regulatory-implementation/. If you have improvements or suggestions, please let us know at CFPB_MortgageRulesImplementation@cfpb.gov