Hi everyone!
Just wanted to let you know, that I've moved to another RE/MAX office. My new company is more in line with my methods and personality of doing business, now that 6 years have gone by. And closer to home, since we moved from Weymouth to Abington last year. So it's a great feeling. You can still reach me the same way, same website, same e-mail, same mobile phone number. Still doing business in the same locations!
Jill Fairweather, Realtor, Broker, CBR, e-PRO, GRI
RE/MAX Realty Advisors
320 Washington St. Norwell, MA 02061
Thursday, September 24, 2009
Saturday, September 5, 2009
Revised TILA Disclosure Requirements Take Effect on July 30, 2009
The National Association of REALTORS® has released the following information on these new rules:
Lenders will be subject to new disclosure requirements for mortgage loans under the Federal Reserve Board Truth in Lending Regulation (Reg Z). The new requirements apply to loan applications filed on or after July 30, 2009 (about two months earlier than originally planned). The new rules are complex and compliance will be a challenge for lenders.
Here are key highlights of the changes:
• The new requirements apply to all mortgages secured by a borrower's home, including primary and second homes and refinancing. Investor loans continue to be exempt.
• Lenders must give good faith estimates of mortgage loan costs within 3 business days after the consumer applies for a loan (early disclosure). The lender may not collect any fees before the disclosure is provided, except for a reasonable fee for obtaining a credit report.
• The closing may not take place until expiration of a 7 day waiting period after the consumer receives the early disclosure.
• Consumers may shorten or waive the 3-day and/or 7-day, waiting periods for a "bona fide personal financial emergency," but only after receiving an accurate TILA disclosure. In the final rule's preamble, the Fed stated that it "believes waivers should not be used routinely to expedite consummation for reasons of convenience." The Fed decided not to insulate lenders from liability even where a consumer modifies or waives the waiting periods.
• If the annual percentage rate (APR) changes by more than 0.125 percent, the lender must provide a corrected disclosure to the borrower and wait an additional 3 business days before closing the loan. The APR includes not only the interest rate on the loan but certain other costs related to settlement, so it will be important for any fees that affect the APR to be as accurate as possible, as early as possible, to minimize the need for a corrected TILA disclosure.
• For additional information you can go to Federal Reserve Board Final Rule and Staff Commentary (Federal Register, May 19, 2009)
http://edocket.access.gpo.gov/2009/pdf/E9-11567.pdf
Lenders will be subject to new disclosure requirements for mortgage loans under the Federal Reserve Board Truth in Lending Regulation (Reg Z). The new requirements apply to loan applications filed on or after July 30, 2009 (about two months earlier than originally planned). The new rules are complex and compliance will be a challenge for lenders.
Here are key highlights of the changes:
• The new requirements apply to all mortgages secured by a borrower's home, including primary and second homes and refinancing. Investor loans continue to be exempt.
• Lenders must give good faith estimates of mortgage loan costs within 3 business days after the consumer applies for a loan (early disclosure). The lender may not collect any fees before the disclosure is provided, except for a reasonable fee for obtaining a credit report.
• The closing may not take place until expiration of a 7 day waiting period after the consumer receives the early disclosure.
• Consumers may shorten or waive the 3-day and/or 7-day, waiting periods for a "bona fide personal financial emergency," but only after receiving an accurate TILA disclosure. In the final rule's preamble, the Fed stated that it "believes waivers should not be used routinely to expedite consummation for reasons of convenience." The Fed decided not to insulate lenders from liability even where a consumer modifies or waives the waiting periods.
• If the annual percentage rate (APR) changes by more than 0.125 percent, the lender must provide a corrected disclosure to the borrower and wait an additional 3 business days before closing the loan. The APR includes not only the interest rate on the loan but certain other costs related to settlement, so it will be important for any fees that affect the APR to be as accurate as possible, as early as possible, to minimize the need for a corrected TILA disclosure.
• For additional information you can go to Federal Reserve Board Final Rule and Staff Commentary (Federal Register, May 19, 2009)
http://edocket.access.gpo.gov/2009/pdf/E9-11567.pdf
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