RESPA/TILA Integration

Part II: Closing Disclosure and Action Plan 

(Including Closing Disclosure Table)


Commentary and Analysis

December 22, 2014
General Requirements









Our Websites-1

Contact Us-1-Beveled-160

This second in a four-part White Paper series details the features of the Closing Disclosure. I also provide an Action Plan.  


Accompanying this article is a Closing Disclosure Table that may be used for certain itemized categories and action requirements. The table outlines the types of areas of interest in many of the routine requirements of the Closing Disclosure process. Rather than a before-and-after, comparative analysis, the Closing Disclosure Table provides the requirements with the compliance effective date of August 1, 2015.


The first part of the series introduced the RESPA/TILA Integration and treated the numerous features of the Loan Estimate. The third part will be a detailed analysis of the Loan Estimate. The fourth part will provide an in depth scrutiny of the Closing Disclosure.


In the other articles of this four-part series, I will provide charts, tables, form specimens, and annotations for applicable categories and action requirements relating to the RESPA-TILA Integration.  


The full series, and accompanying charts, tables, and form specimens, are being published in National Mortgage Professional Magazine. The December edition contains a complete section devoted to the Closing Disclosure Table.


As a courtesy to our subscribers, we have arranged a free subscription to the e-Edition of the National Mortgage Professional Magazine.


I hope you enjoy the White Paper and accompanying Closing Disclosure Table.


Best wishes to our clients, colleagues, and subscribers for a joyous Holiday Season and New Year!

President and Managing Director   
Visit our blog

Download Article-Square-Red (150x150)

If the loan requires a Loan Estimate, creditors must also provide the Closing Disclosure, to be received by the consumer no later than three business days before consummation of the loan.


A practical way to view the Closing Disclosure is as a consolidation of the HUD-1 and the final TIL disclosure, containing additional elements. There are four rudimentary requirements of the Closing Disclosure.

Download Article-Square-Red (150x150)

Because the three-day waiting period rule uses "consummation" as the triggering event, we have often been asked for the difference between consummation and closing or settlement.


Actually, consummation may commonly occur at the same time as closing or settlement, but it is a legally distinct event. Consummation occurs when the consumer becomes contractually obligated to the creditor on the loan, not, for example, when the consumer becomes contractually obligated to a seller on a real estate transaction. 

LENDERS COMPLIANCE GROUP is the first full-service, mortgage risk management firm in the United States specializing exclusively in outsourced mortgage compliance and offering a full suite of services in residential mortgage banking for banks and non-banks. We are pioneers in outsourcing solutions for residential mortgage compliance. We offer our clients real-world, practical solutions to mortgage compliance issues, with an emphasis focused on operational assessment and improvement, benchmarking methodologies, Best Practices, regulatory compliance, and mortgage risk management.
This newsletter is free to subscribers, clients, and colleagues, who also regularly receive our free Mortgage Compliance Updates, Publications Notices, and Commentaries.
Information contained in this email is not intended to be and is not a source of legal advice. The views expressed are those of the contributing author, as well as news services and websites linked hereto, and do not necessarily reflect the views or policies of Lenders Compliance Group, any governmental agency, business entity, organization, or institution. Lenders Compliance Group makes no representations concerning and does not guarantee the source, originality, accuracy, completeness, or reliability of any statement, information, data, finding, interpretation, advice, opinion, or view presented herein.
2014 Lenders Compliance Group, Inc. All Rights Reserved.
      167 West Hudson Street - Suite 200 | Long Beach | New York | 11561 | (516) 442-3456