Due to increased appraisal turn - times and significant overhaul to
updated loan disclosure forms and regulatory waiting periods, best industry practice is to add 15 days to standard 30 day timelines for non-cash buyers that require mortgage financing (i.e. contractual closing date of approximately 45 days if no additional contingencies or requirements).
Not exact matches
As of Friday, February 23, 2018, recent
updates made to the Truth in Lending
disclosure statement for unsecured consumer
loans will take effect.
Because the document must be disclosed to borrowers at least three business days before their closing, the need for an
updated disclosure could delay your originally scheduled
loan closing.
The CFPB deemed these forms too confusing because fees, calculations, and explanations were spread across two separate multi-page
disclosures, so the bureau
updated the forms effective with all
loan applications after October 3, 2015.
The lone industry commenter to argue that industry could successfully implement the final rule within 12 months asserted that such a period should be more than sufficient for industry to implement the new
disclosures and
update technology and software programs, as the current
disclosure forms are already implemented in all
loan origination software and could be
updated quickly.
Because creditors will be
updating software and compliance systems for these two
disclosures at the same time as and in conjunction with the
updating for the
Loan Estimate and the Closing Disclosure, the
disclosures should be relatively easy to implement and the additional costs are likely to be minimal.