CFPB TRID Sec. 3 - Can a creditor use the Integrated Disclosures for applications received before October 3, 2015?

Compliance > Regulation Z - TILA / TRID Specific > General Info
Q:  Can a creditor use the Integrated Disclosures for applications received before October 3, 2015?
 
A:  No. For transactions where the application is received prior to October 3, 2015, creditors will still need to follow the disclosure requirements under Regulations X and Z as they existed before the Integrated Disclosures were created by the TILA-RESPA Rule. A creditor will need to use the Truth-in-Lending disclosures, GFE, HUD-1, etc., as applicable, for those transactions.
 
 
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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