Regulation Z Disclosure Changes

Here is an item by item listing of the disclosures pursuant to new changes to Regulation Z, aka “The Truth in Lending Act” and when they are disclosed:

At time of application:

• “Key Questions to Ask About Your Mortgage” pamphlet
• “Fixed vs. Adjustable Rate Mortgages” pamphlet, which would replace the “Consumer Handbook on Adjustable-Rate Mortgages” booklet.
•  Revised ARM-loan-program disclosure with terms in a question –and – answer format.

 Within three days of application:

• Revised early Truth in Lending Act (TILA) disclosure, which also would be required three days before charging any fees other than those for credit reports.
• New calculations for annual percentage rates and finance charges to be more inclusive of third-party charges.
• Column comparison of interest rates for borrowers with varying credit grades.
• Summary of key loan features, total settlement costs and potential changes to interest rate and monthly payment

 Three days before consummation:

• Final TILA disclosure
• Procedures for disclosing loan changes after the final TILA

After consummation, note that the time period for notice of changes to ARM’s is now 60 days, and more-detailed statements are required for payment-option ARMS.