By: Gina Ellis
The CFPB has released “Your Home Loan Toolkit,” a new consumer guide that replaces the current Settlement Cost booklet. You will now be required to provide this Toolkit to consumers beginning August 1, 2015, yet the requirements for providing the Toolkit do not change. As usual, the Toolkit is required to be delivered to the consumer no later than three business days after receiving a completed application secured by real property for the purpose of purchasing 1-4 family residential property. If the application is denied before the end of the three business day period, delivery of the Toolkit is not required.
We recommend you make plans to remove any old Settlement Cost booklets you have distributed to loan officers and update any links available on your website on the August 1st effective date. Even if a transaction falls under the old mortgage disclosure rules, for example when a lender originates fewer than five mortgages in the preceding year, the new Toolkit will be required.
The new Toolkit includes interactive features consumers can use to evaluate their financial situation, understand the mortgage process and shop for the best loan features. Because consumers may have questions about this evaluation process, it is best to include a review of the new Toolkit when training loan personnel for the new integrated disclosure requirements. If you decide to deliver the Toolkit and other required early disclosures electronically, make sure your procedures are compliant with the E-SIGN Act by delivering the required disclosures prior to obtaining affirmative consent electronically.