Link to CFPB Sample Real Estate Closing Forms.
Posted By Cliff Tuttle | March 23, 2015
No. 1,130
Here’s a link to the new sample forms promulgated by the CFPB (Consumer Financial Protection Bureau) for real estate closing disclosures that will be required for loans originated after August 1, 2015.
If you are accustomed to using the HUD 1 settlement statement, you’ll find the essence of it integrated into the various combined Truth in Lending and Real Estate Settlement Procedures Act Disclosures. But the HUD 1 itself will cease to exist.
These documents are intended to make loan disclosures more easily understood. But do they, really? The CFPB thinks they represent an improvement in clarity over prior disclosure forms. And perhaps that is true in the abstract.
But in practice, the typical borrower will zone out somewhere on page 2. People will need to have the information on these forms explained line by line, just as they do now. This used to be done at the closing table. Now, with disclosures being given three days in advance, clients who want understandable explanations of the disclosures may call their lawyers. Even though they are not conducting residential loan closings under the new regime, real estate lawyers should be prepared to assist bewildered borrowers before and perhaps during the closing.
Its too late to complaint. These changes are a done deal, or at least they seem to be. Nevertheless, if history is a reliable guide, the CFPB will postpone the implementation date, possibly more than once.
CLT