CFPB TRID Sec. 4 - What are the disclosure obligations for transactions not covered by the TILA-RESPA Rule, like HELOCs and reverse mortgages?

Compliance > Regulation Z - TILA / TRID Specific > General Info
Q:  What are the disclosure obligations for transactions not covered by the TILA-RESPA Rule, like HELOCs and reverse mortgages?
 
A:  The Integrated Disclosures will not be used to disclose information about reverse mortgages, HELOCs, chattel-dwelling loans, or other transactions not covered by the TILA-RESPA Rule. Creditors originating these types of mortgages must use, as applicable, the GFE, HUD-1, and Truth-in-Lending disclosures.
 
For transactions that satisfy the six criteria for the partial exemption associated with certain housing assistance loans for low- and moderate-income consumers (§ 1026.3(h)):
 
  • Creditors are exempt from the requirement to provide the RESPA settlement cost booklet, GFE, settlement statement (HUD-1), and application servicing disclosure statement. ( See §§ 1024.5(d)(2), 1024.6, 1024.7, 1024.8, 1024.10, and 1024.33)
  • Creditors are exempt from the requirement to provide the Special Information Booklet. (§ 1026.3(h))
  • Creditors are exempt from the requirement to provide the Loan Estimate and Closing Disclosure if they choose to provide the Truth-in-Lending disclosures in connection with the transaction. (§ 1026.3(h)(6)).
 
For more information on the partial exemption associated with certain housing assistance loans, see section 4.5 of the Bureau’s compliance guide.
 
 
This can be found in the CFPB's TILA-RESPA Integrated Disclosure rule compliance guide - http://www.consumerfinance.gov/regulatory-implementation/tila-respa/
 

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