AMERICAN BAR ASSOCIATION CONSUMER FINANCIAL SERVICES COMMITTEE SPRING MEETING SAN FRANCISCO, CALIFIORNIA

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1 AMERICAN BAR ASSOCIATION CONSUMER FINANCIAL SERVICES COMMITTEE SPRING MEETING SAN FRANCISCO, CALIFIORNIA TILA-RESPA INTEGRATED DISCLOSURE RULE BACKGROUND, TILA LIABILITIES & OPERATIONAL CONCERNS I. OVERVIEW April, 2015 The Consumer Financial Protection Bureau s ( CFPB ) TILA-RESPA Integrated Disclosure rule ( TRID or the Rule ) 1 is a wide ranging and comprehensive overhaul of the current early application and final closing disclosure frameworks previously developed by the Federal Reserve Board, when administering the Truth-in-Lending Act ( TILA ), and HUD, when administering the Real Estate Settlement Procedures Act ( RESPA ). The Dodd-Frank Act transferred administrative authority over TILA and RESPA to the CFPB and required the CFPB to build one cohesive disclosure framework. TRID is the CFPB s vehicle for merging the Good Faith Estimate ( GFE ) and HUD-1 RESPA disclosures with the early and final TILA disclosures. Industry has long hoped for resolution of the many conflicting and sometimes confusing overlap between TILA and RESPA disclosure requirements, however, TRID goes beyond simply clarifying these issues. Although TRID borrows many of the existing TILA and RESPA disclosure concepts, TRID is a complete replacement of the existing disclosure frameworks that has significant impacts on disclosure timing, content, operations and relationships with vendors. Under TRID, the Loan Estimate is now the early application disclosure and the Closing Disclosure is the final closing disclosure. These are model forms in name only for most loans. That is, model forms H-24 and H-25 must be used for closed-end consumer credit transactions secured by real property that are not reverse mortgages and are federally related mortgage loans. 2 Most important from a legal risk perspective, the CFPB used existing and new TILA statutory authorities for incorporating into Regulation Z many of the disclosure and delivery elements originally required by RESPA. This means that many of the disclosure 1 A copy of the final rule may be obtained here: 2 Loan Estimate and Closing Disclosure samples may be reviewed here: Copyright 2015 Alston & Bird LLP

2 elements in the old GFE and HUD-1 forms are now possibly subject to TILA s statutory civil liability provisions, including private rights of action, class action liability, and assignee liability. To state it another way, all disclosure, delivery, timing and content requirements are now in Regulation Z and may be subject to the liabilities provided by TILA, including the aforementioned private rights of action. Prior to the promulgation of TRID, violations of the RESPA disclosure and delivery elements implemented by HUD in the Good Faith Estimate and the HUD-1 were not subject to such private rights of action and assignee liability. TRID clearly makes the creditor responsible for compliance (the settlement agent could have responsibility for the seller s portion of the form in a purchase money transaction). Even if a mortgage broker provides the Loan Estimate, for example, the creditor is still ultimately responsible if the form was not properly delivered. New content includes dynamic disclosure elements that are only included in the form if applicable, otherwise they cannot be included at all. As a practical matter, this means there can be little to no hard-coded content with an N/A or a blank next to it. That is, static disclosures, where the entire tag for a given disclosure item is listed in every form regardless of whether the disclosure is applicable, may not be permitted. Also, the form contains more fee itemization on the second page in the new Loan Costs and Other Costs tables, similar to the original GFE issued before the HUD s 2008 RESPA Reform Rule. However, each fee generally must be labeled and listed alphabetically and the same fee tag must be used for the same service. Thus, creditors must work with settlement service providers to coordinate fee naming conventions for a given service. In some cases, settlement service providers are also vendors from a vendor management and oversight perspective. Another new disclosure to note involves the borrower s personal foreclosure liability. This requires a statement regarding potential loss of protections when the borrower refinances, such as whether the borrower s liability is no longer limited to the value of the security property as may be the case under certain state laws. In effect, this requires the creditor to understand whether a given state has anti-deficiency judgment or homestead laws in place (as applicable) for determining which disclosure applies in the model disclosure form. TRID also replaces tolerances, which were used in the RESPA GFE and HUD framework for closing costs, with a new good faith estimate standard and specific variance exceptions. The good faith estimate standard is the baseline that every disclosure closing cost item must meet unless a specified variance exception applies. An estimated closing cost disclosed in the Loan Estimate is in good faith if the actual charge paid by or imposed on the consumer does not exceed the amount originally disclosed in the Loan Estimate. These fees include fees paid to the creditor, mortgage broker, affiliate of either, or an unaffiliated third party if the creditor did not permit the consumer to shop for a third party service provider for that settlement service and transfer taxes. Fees that are permitted to increase by no more than a 10% variance in the aggregate include recording fees and charges paid to a third party that is not the creditor 2

3 or an affiliate of the creditor for providing services required by the lender for which the consumer is permitted to shop. Other fees, permitted to increase by any amount so long as the estimate is consistent with the best information reasonably available to the creditor at the time it is disclosed, are: prepaid interest, property insurance premiums, amounts placed into an escrow, impound, reserve, or similar account, charges paid to third-party service providers for lender required services the consumer is permitted to shop for and selected by the consumer that are not on the required written shopping list and charges paid for third-party services not required by the creditor. These charges may be paid to affiliates of the creditor. This document is up to date with notable TRID revisions finalized by the CFPB as of January 20, We expect the CFPB to issue additional revisions and guidance as more and varied industry stakeholders move to implement the TRID requirements and apply them in practice. II. TRID RULE DISCLOSURE DEVELOPMENT The Dodd-Frank Act transferred interpretive authority over RESPA, TILA and a broad array of other federal regulations to the CFPB. The Dodd-Frank Act also directed the CFPB to integrate the early and final mortgage disclosures mandated under RESPA sections 4 and 5 and Regulation X (which implements RESPA) and TILA and Regulation Z (which implements TILA). More than three years ago under then CFPB Acting Director, Elizabeth Warren, the Know Before You Owe project commenced and the CFPB began to draft prototype integrated disclosures and test them throughout the United States. Early goals for the project included: providing accessible information so consumers can make informed decisions and more easily comparison shop for loans, reducing surprises at the closing table and limiting payment shock years later after closing. For this purpose, the CFPB engaged a plain language communications consulting firm, graphic design artists and marketing and consumer behavior scholars to assist in the creation of the initial prototypes. The forms were then improved through an iterative process involving multiple rounds of qualitative and quantitative consumer testing. The CFPB also made it a point to include loan officers or mortgage brokers in nearly every round of testing. The CFPB conducted 10 rounds of qualitative prototype testing in 9 different cities between May 2011 and March 2012 (92 consumers and 22 industry participants). Four rounds of Spanish-language testing were also conducted. Approximately 27,000 comments were received during the Know Before You Owe input phase that opened online in May Proposed rules were issued on July 9, 2012 and the comment period 3 A complete version of the TRID revisions issued on January 20, 2015 may be obtained here: 3

4 closed in November The CFPB reviewed over 3,000 comments received during the official Administrative Procedures Act comment period. The CFPB issued the final TILA-RESPA Integrated Disclosure rule on November 20, As a result of the extensive consumer testing, stakeholder input, formal comments and statutory mandates, the CFPB issued two new integrated disclosures (not a single integrated disclosure per se) under Regulation Z. The Loan Estimate and Closing Disclosures generally incorporate less text and more graphics. The content, information ordering and format of the forms in the CFPB s view are paramount to consumer understanding and action based on the information provided. Because of the design and dynamic nature of the disclosures, more complex products and products with more itemized fees look more complex and costly to consumers. Important information is generally disclosed at the front of the disclosures. Educational components were left out of the forms. The CFPB endeavors to create separate tools to address those needs. Besides the disclosure content, the new Regulation Z provisions also contain new timing, delivery and responsibility requirements. For purposes of triggering the early disclosure (i.e., providing the Loan Estimate) delivery requirement a loan application is made when a mortgage lender or broker receives the applicant s name, income, social security number, property address, estimated value of the property and mortgage loan amount sought. In a departure from the proposed rule, the final rule provides that re-disclosure and a new 3-day waiting period only applies if the APR increases by more than 1/8 th of 1%, the loan product changes, or a prepayment penalty is added. Other changes may be disclosed on a revised Closing Disclosure without delaying the closing. The final rule also includes Spanish versions of the Loan Estimate and Closing Disclosure and specifies that settlement agents rather than lenders may provide the Closing Disclosure. III. EFFECTIVE DATE The final rule takes effect on August 1, IV. WHAT/WHO DOES THE RULE APPLY TO? Generally, the Rule applies to most closed-end consumer mortgages. However, it does not apply to home-equity lines of credit, reverse mortgages, loans secured by mobile homes or dwellings not attached to real property, and lenders that make five or fewer mortgages a year. TRID also does not apply to specified no-interest second mortgage loans made for the purpose of property rehabilitation, energy efficiency, foreclosure avoidance, or downpayment assistance. LIABILITY A. General TILA Creditor Liability Overview 4

5 1. TILA (a) (b) Provides a private right of action Remedies include: i. Actual damages ii. Statutory damages up to $4,000 per violation iii. Class action damages lesser of $1,000,000 or 1% of company value iv. Attorney s fees and court costs v. Administrative enforcement (c) Incorrect technical errors programmed into each disclosure could be easy class actions 2. RESPA (a) RESPA No express private rights of action under either section 4 or 5 of i. Subject to enforcement action by a host of federal and state governmental authorities, and face the possible imposition of civil money penalties. ii. Subject to claims arising under state law, such as state deceptive acts and practices statutes. B. General TILA Assignee Liability Overview 1. TILA (a) Civil action for a violation of the consumer credit cost disclosure requirements of TILA or an administrative enforcement proceeding described in section 1607 of TILA, which may be brought against a creditor, with respect to a consumer credit transaction secured by real property, may be maintained against any assignee of such creditor only if: i. the violation for which such action or proceeding is brought is apparent on the face of the disclosure statement, and ii. the assignment to the assignee was voluntary. 5

6 (b) A violation is apparent on the face of the disclosure statement if: i. the disclosure can be determined to be incomplete or inaccurate by a comparison among the disclosure statement, any itemization of the amount financed, the note, or any other disclosure of disbursement; or ii. the disclosure does not use the required terms or format. 2. RESPA (a) A violation of RESPA does not impair the validity of a loan, or expose a true secondary market purchaser of a loan to assignee liability. C. New TRID TILA vs. RESPA Liability? 1. Background/Summary ALL Loan Estimate and Closing Disclosure, delivery, timing and content requirements are codified in Regulation Z and may be subject to the liabilities provided by TILA, including private rights of action. The CFPB indicated in the Rule that a determination of whether Regulation Z liability applies depends on the specific authorization relied on for each provision of the rule (i.e., RESPA or TILA). Thus, a provision by provision analysis is required to determine liability. [Note, however, that the specific authorization for each provision is unclear in some cases.] The Dodd-Frank Act provisions the CFPB relied upon for authorization to promulgate TRID provide little, if any, additional guidance for liabilities. However, TILA, as amended by the Dodd-Frank Act, requires disclosure of the aggregate amount of settlement services and other costs. [new TILA section 128(a)(17) requires the following disclosure: in the case of a residential mortgage loan, the aggregate amount of settlement charges for all settlement services provided in connection with the loan, the amount of charges that are included in the loan and the amount of such charges the borrower must pay at closing, the approximate amount of the wholesale rate of funds in connection with the loan, and the aggregate amount of other fees or required payments in connection with the loan ]. Thus, for example, section (f) of the Rule, which sets forth the settlement services cost provisions of the Loan Estimate most similar to Regulation X and the current Good Faith Estimate could reasonably be argued as being subject to TILA and RESPA liability given that each individual cost is necessary for disclosing the aggregate amounts of the costs required by TILA, depending on the nature of each cost. The following discussion items include possible sources for TILA liability and related disclosure provisions: (a) The preamble of the Rule does not specifically state which liabilities apply which elements of the disclosure. The CFPB notes that it addresses statutory authority relied upon for each requirement, and that this 6

7 provides sufficient guidance for liabilities. The authority for the integrated disclosure provisions is based on specific disclosure mandates in TILA and RESPA, as well as certain rulemaking and exception authorities granted to the Bureau by TILA, RESPA, and the Dodd-Frank Act. The details of the Bureau s use of such authority are described in the section-by-section analysis. The Bureau believes these detailed discussions of the statutory authority for each of the integrated disclosure provisions provide sufficient guidance for industry, consumers, and the courts regarding the liability issues raised by the commenters. i. The section-by-section analysis for section generally, states: the Bureau adopts revised and comment 37 1, and comment 37 2 as proposed, pursuant to its authority under TILA section 105(a) and RESPA section 19(a), because the Bureau believes these provisions will promote the informed use of credit and more effective advance disclosure of settlement costs. ii. The section-by-section analysis for subsection (f), which sets forth the content requirements for the Loan Costs section under the Closing Cost Details master heading states that under section 5(c) of RESPA creditors must provide applicants for federally related mortgage loans with a good faith estimate of the amount or range of charges for specific settlement services the applicant is likely to incur in connection with the settlement of the loan. 12 U.S.C. 2604(c)... As discussed above, Dodd-Frank Act section 1032(f) requires that the Bureau propose rules to combine these RESPA disclosures with the disclosures required by TILA. In addition to existing TILA disclosure requirements, section 1419 of the Dodd-Frank Act amended TILA section 128(a) to require, in the case of a residential mortgage loan, disclosure of the aggregate amount of settlement charges for all settlement services provided in connection with the loan and the aggregate amount of other fees or required payments in connection with the loan. 15 U.S.C. 1638(a)(17)... Proposed (f) and (g) would have implemented these early disclosure requirements of TILA and RESPA by setting out details relating to the costs for consummating the mortgage loan, separated into two categories: loan costs and other costs... The Bureau believed that these disclosures would have effectuated the purpose of TILA by promoting the informed use of credit and assuring a meaningful disclosure to consumers. The Bureau believed that the disclosures also would have satisfied the RESPA requirement to provide a consumer with a good faith estimate of the amount or range of charges for specific settlement services the consumer is likely to incur in connection with the settlement. In addition, these disclosures would have ensured that the features of the mortgage loan transactions are fully, accurately, and effectively disclosed to consumers in a manner that permits consumers to understand the costs, benefits, and risks associated 7

8 with the mortgage loan transaction, in light of the facts and circumstances, consistent with Dodd-Frank Act section 1032(a) [requires the integration of the TILA and RESPA disclosures]... Accordingly, the Bureau is adopting the general requirement that an itemized list of fees and charges be disclosed and (f) and its accompanying commentary generally as proposed, except to the extent that amendments are made to the subparagraphs and accompanying commentary as described below. (b) as follows: Section 1098 of the Dodd-Frank Act amended section 4 of RESPA The Bureau shall publish a single, integrated disclosure for mortgage loan transactions (including real estate settlement cost statements) which includes the disclosure requirements of this section and section 5, in conjunction with the disclosure requirements of the Truth in Lending Act that, taken together, may apply to a transaction that is subject to both or either provisions of law. The purpose of such model disclosure shall be to facilitate compliance with the disclosure requirements of this title and the Truth in Lending Act, and to aid the borrower or lessee in understanding the transaction by utilizing readily understandable language to simplify the technical nature of the disclosures. (c) Section 1098 of the Dodd-Frank Act amended section 5(a) of RESPA as follows: The Bureau shall prepare and distribute booklets jointly addressing compliance with the requirements of the Truth in Lending Act and the provisions of this title, in order to help persons borrowing money to finance the purchase of residential real estate better to understand the nature and costs of real estate settlement services. (d) Section 1100A(5) of the Dodd-Frank Act amended section 105(b) of TILA as follows: The Bureau shall publish a single, integrated disclosure for mortgage loan transactions (including real estate settlement cost statements) which includes the disclosure requirements of this title in conjunction with the disclosure requirements of the Real Estate Settlement Procedures Act of 1974 that, taken together, may apply to a transaction that is subject to both or either provisions of law. The purpose of such model disclosure shall be to facilitate compliance with the disclosure requirements of this title and the Real Estate Settlement Procedures Act of 1974, and to aid the borrower or lessee in understanding the transaction by utilizing readily understandable language to simplify the technical nature of the disclosures. (e) Section 1032 of the Dodd-Frank Act provides no additional liability guidance: 8

9 Not later than 1 year after the designated transfer date, the Bureau shall propose for public comment rules and model disclosures that combine the disclosures required under the Truth in Lending Act and sections 4 and 5 of the Real Estate Settlement Procedures Act of 1974, into a single, integrated disclosure for mortgage loan transactions covered by those laws, unless the Bureau determines that any proposal issued by the Board of Governors and the Secretary of Housing and Urban Development carries out the same purpose. (f) Previously, GFE and HUD-1 elements were authorized under sections 4 and 5 of RESPA. These sections of RESPA have no private right of action. Liability for such violations mostly arises from administrative enforcement and possible private rights of action through other federal and state UDAP related laws. V. PRELIMINARY OPERATIONAL CONCERNS CHECKLIST A. Pre-application activity 1. Mandatory disclosure on written estimates and worksheets of terms or costs specific to the consumer (a) Your actual rate, payment, and costs could be higher. Get an official Loan Estimate before choosing a loan (b) What materials does the lender provide that would be considered to be an estimate for these purposes? Must be determined and the disclosure applied. B. Dynamic Disclosures 1. Vary according to product 2. Adjustable loan terms 3. Labeling critical alphabetized fees/same fee names for related service 4. Fee naming conventions when working with settlement service providers service (a) Different providers may use different fee names for the same 5. Limited number of hard-coded lines (a) If disclosure isn t applicable, disclosure tag (placeholder) does not appear; generally no N/A or blank lines next to hard-coded disclosure tag permitted. 9

10 6. 3, 2, 1 Decimal places/rounding for percentages and dollar values (2 decimal places or truncated) 7. Escrows 8. Good faith estimate default standard/variances C. Different definitions for business days D. Working with Settlement Agent/Service Providers 1. Settlement Agent collects seller information but lender could be responsible for certain portions of the Closing Disclosure for the borrower that includes information from the seller s part of the transaction 2. Settlement agent responsible for providing seller disclosures 3. If the lender is relying on the settlement agent to provide the Closing Disclosure, in general must provide all information to the settlement agent in time for the settlement agent to prepare the Closing Disclosure 3 days prior to closing dates on documents must meet timing requirements 4. Settlement agents and providers likely subject to creditor vendor management and oversight requirements, in some cases even if the consumer chooses them 5. Must provide written list of providers disclosure if shopping permitted E. Contact information for entities and individuals 1. Persons responsible for providing the disclosures must coordinate to obtain information regarding the following entities and related individuals involved in the transaction to include such information on the disclosures, as applicable: (a) (b) (c) Real estate brokers Closing agents Mortgage broker loan officers 10

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