TILA-RESPA Integrated Disclosures – FAQ
Our compliance, lending and mortgage fulfillment teams have worked hard to reshape how we do business in light of the changes the TILA-RESPA Integrated Disclosures rule put in place. Ensuring we continue to serve our customers throughout this process is a top priority for all of us. We also want to provide you with support during this process so that you can be ready for the impact of this new rule as well.
Frequently Asked Questions:
Will HomeTrust be able to give my customers pre-qualification or pre-approval letters?
We will continue to provide resources for our customers who require additional documentation to support purchase contracts.
How will the origination process change for my customers?
Changes to the disclosures themselves will be the most significant for customers. The electronic disclosure and e-consent process is also changing, and your customers who have used our system before may notice the difference.
How will the origination process change for me?
The disclosure and delivery timelines under the new rule are very tight. Accurate and timely information is vital to keeping our customers on track. All parties involved in the real estate transaction must be responsive to requests from customers and HomeTrust Bank.
Will there be any impact on closings?
The new Closing Disclosure will combine some of the disclosures customers sign. And a new three day waiting period is being required by the new rule. Last minute changes will likely delay closings.
What else do I need to know about the three day waiting period?
The three day period begins when the customer confirms receipt of the Closing Disclosures or three days after mailing. The three days do not include Sundays or federal holidays (New Year’s Day, MLK Day, Washington’s Birthday, Memorial Day, Independence Day, Labor Day, Columbus Day, Veterans Day, Thanksgiving Day and Christmas Day).
What should we do if the borrower wants to close early?
The waiting period prohibits early closings. However, once our customer confirms receipt of the Closing Disclosure, the waiting period will begin. E-consent of disclosures by the borrower will help speed up the process by confirming receipt.
Will HomeTrust Bank be preparing its own Closing Disclosures(CD)?
We will be preparing the borrower/buyer portion of the Closing Disclosure. We will continue to rely on you and your team for accurate information for completing the Closing Disclosure.
How will our communication with the Settlement Agent work after October 3rd?
All communication will be done securely and in accordance with our Service Level Agreement, which will be provided to you and must be on file at HomeTrust Bank prior to closing.
When will the Closing Disclosure begin being prepared?
We will begin communications ten days prior to the scheduled closing date.
Will the Settlement Agent receive a copy of the CD that HomeTrust Bank prepares?
A copy of the final Closing Disclosure will be forwarded to the Settlement Agent for record keeping purposes.
Can I refer customers to HomeTrust Bank for questions I don’t know how to answer?
Our compliance, sales, and mortgage fulfillment teams have all worked diligently to prepare for this new rule and are happy to help answer any questions you might have. Contact information for questions can be found below.
Have Additional Questions?
If you have questions not covered above, please email our TILA-RESPA transition team.
