Sifting Through Reg Z Changes
By Marsha Williams, Attorney, MRG
Lenders need to understand the recent legislative and regulatory changes affecting the disclosure process in order to avoid potential delayed closings and loss of originations.
The Mortgage Disclosure Information Act expands the requirements for early disclosures. The most notable requirement of MDIA is that if the annual percentage rate provided in the early good-faith estimate disclosures changes beyond the specified TILA tolerance for accuracy under Regulation Z (one-eighth of one percent for a regular transaction or one-fourth of one percent for an irregular transaction), lenders must provide revised disclosures, which the consumer must receive on or before the third business day before consummation of the transaction.
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