1. Understanding
the CFPB Final Rule on
Integrated Disclosures
Presented by: Noah Blanton
January, 2014
1

2. Disclaimer
Today’s Topics
- About the CFPB
-History of Disclosures
Effective Date
About the CFPB
- Loan Estimate
Mortgage Rules
- Closing Disclosure
- Service Providers
- Delivery Alternatives
The information in this presentation, event and/or printed material is provided for informational
purposes only. None of the materials or opinions is offered, or should be construed, as legal
advice. Communication of information by or through these means and your receipt or use of
such information is not to be construed as legal advice or to constitute an attorneyclient relationship.
- QM / ATR
- - Three-DayDisclosures
Rule
Integrated
-Final Rule
All-In APR
-Loan Estimate
Electronic Storage
Refinance
- - Proposals Not
Closing Disclosure
Adopted
- Purchase – Buyer
- Purchase - Seller
Resources
Takeaways
You should not act or rely upon information contained in these materials without specifically
seeking professional legal advice. Additional resources that may be referenced in the following
presentation or materials are offered merely as a convenience to participants with no guarantees
made as to the applicability or validity of the third-party content. We do not take any
responsibility for the content, accuracy or timeliness of referenced websites, articles, books,
events, etc.; nor do we endorse any commercial products that may be advertised or available on
those sites.
What Lies Ahead?
Q&A
Stewart endeavors to comply with all applicable legal and ethical requirements when providing
information to industry participants.
© Copyright Stewart 2014
2

3. History of Disclosures – Truth-in-Lending
Today’s Topics
- About the CFPB
-History of Disclosures
Effective Date
About the CFPB
- Loan Estimate
Mortgage Rules
Truth-in-Lending Act (TILA) of 1968
Implemented by Federal Reserve Board
- Closing Disclosure
- Service Providers
- Delivery Alternatives
- QM / ATR
- - Three-DayDisclosures
Rule
Integrated
-Final Rule
All-In APR
-Loan Estimate
Electronic Storage
Refinance
- - Proposals Not
Closing Disclosure
Adopted
Promulgated Regulation Z
Created Truth-in-Lending Statement
Discloses the following:
- Purchase – Buyer
- Purchase - Seller
Cost of credit
Resources
Takeaways
Repayment terms of mortgage
What Lies Ahead?
Q&A
Annual percentage rate (APR)
Loan rate
Fees amortized over expected life of loan
Discloses finance charges, amount financed, total
number of payments, whether interest can change,
whether loan can be refinanced
© Copyright Stewart 2014
3

4. History of Disclosures - RESPA
Today’s Topics
- About the CFPB
-History of Disclosures
Effective Date
Real Estate Settlement Procedures Act of 1974
About the CFPB
- Loan Estimate
Mortgage Rules
- Closing Disclosure
- Service Providers
RESPA was implemented by HUD
- Delivery Alternatives
- QM / ATR
- - Three-DayDisclosures
Rule
Integrated
Promulgated Regulation X
-Final Rule
All-In APR
-Loan Estimate
Electronic Storage
Refinance
- - Proposals Not
Closing Disclosure
Adopted
- Purchase – Buyer
Created Good Faith Estimate
Standardized disclosures of closing costs
- Purchase - Seller
Resources
Takeaways
What Lies Ahead?
Q&A
Included costs associated with mortgages
HUD-1 and GFE modified in 2010
© Copyright Stewart 2014
4

5. The CFPB Timeline
Today’s Topics
- About the CFPB
2007
2008
2009
2010
2011
2012
2013
-History of Disclosures
Effective Date
About the CFPB
- Loan Estimate
Mortgage Rules
- Closing Disclosure
- Service Providers
- Delivery Alternatives
The market peaked in 2007….
- QM / ATR
- - Three-DayDisclosures
Rule
Integrated
-Final Rule
All-In APR
-Loan Estimate
Electronic Storage
Refinance
- - Proposals Not
Closing Disclosure
Adopted
- Purchase – Buyer
- Purchase - Seller
Resources
Takeaways
What Lies Ahead?
Q&A
© Copyright Stewart 2014
5

6. The CFPB Timeline
Today’s Topics
- About the CFPB
2007
2008
2009
2010
2011
2012
2013
-History of Disclosures
Effective Date
About the CFPB
- Loan Estimate
Mortgage Rules
- Closing Disclosure
- Service Providers
- Delivery Alternatives
Officially dubbed “Financial Collapse” in 2008
- QM / ATR
- - Three-DayDisclosures
Rule
Integrated
-Final Rule
All-In APR
-Loan Estimate
Electronic Storage
Refinance
- - Proposals Not
Closing Disclosure
Adopted
- Purchase – Buyer
- Purchase - Seller
Resources
Takeaways
What Lies Ahead?
Q&A
© Copyright Stewart 2014
6

7. The CFPB Timeline
Today’s Topics
- About the CFPB
2007
2008
2009
2010
2011
2012
2013
-History of Disclosures
Effective Date
About the CFPB
- Loan Estimate
Mortgage Rules
- Closing Disclosure
- Service Providers
- Delivery Alternatives
- QM / ATR
- - Three-DayDisclosures
Rule
Integrated
-Final Rule
All-In APR
-Loan Estimate
Electronic Storage
Refinance
- - Proposals Not
Closing Disclosure
Adopted
- Purchase – Buyer
- Purchase - Seller
Resources
Takeaways
What Lies Ahead?
Q&A
The push for financial
regulatory reform
began in 2009
© Copyright Stewart 2014
7

8. The CFPB Timeline
Today’s Topics
- About the CFPB
2007
2008
2009
2010
2011
2012
2013
-History of Disclosures
Effective Date
About the CFPB
- Loan Estimate
Mortgage Rules
- Closing Disclosure
- Service Providers
- Delivery Alternatives
- QM / ATR
- - Three-DayDisclosures
Rule
Integrated
-Final Rule
All-In APR
-Loan Estimate
Electronic Storage
Refinance
- - Proposals Not
Closing Disclosure
Adopted
- Purchase – Buyer
- Purchase - Seller
Resources
Takeaways
What Lies Ahead?
Q&A
© Copyright Stewart 2014
8

9. About the CFPB
2007
Today’s Topics
- About the CFPB
2008
2009
2010
2011
2012
2013
-History of Disclosures
Effective Date
About the CFPB
- Loan Estimate
Mortgage Rules
- Closing Disclosure
- Service Providers
- Delivery Alternatives
- QM / ATR
- - Three-DayDisclosures
Rule
Integrated
-Final Rule
All-In APR
-Loan Estimate
Electronic Storage
Refinance
- - Proposals Not
Closing Disclosure
Adopted
- Purchase – Buyer
- Purchase - Seller
Resources
Takeaways
What Lies Ahead?
Q&A
CFPB formed with Richard Cordray as Director
Supervisory authority over Banks and Non-Banks.
Enforcement authority over RESPA and TILA
-
© Copyright Stewart 2014
9

10. The CFPB Timeline
Today’s Topics
- About the CFPB
2007
2008
2009
2010
2011
2012
2013
-History of Disclosures
Effective Date
About the CFPB
- Loan Estimate
Mortgage Rules
- Closing Disclosure
- Service Providers
- Delivery Alternatives
Proposed and finalized many rules in 2012
- QM / ATR
- - Three-DayDisclosures
Rule
Integrated
-Final Rule
All-In APR
-Loan Estimate
Electronic Storage
Refinance
- - Proposals Not
Closing Disclosure
Adopted
- Purchase – Buyer
- Purchase - Seller
Resources
Takeaways
What Lies Ahead?
Q&A
© Copyright Stewart 2014
10

11. The CFPB Timeline
Today’s Topics
- About the CFPB
2007
2008
2009
2010
2011
2012
2013
-History of Disclosures
Effective Date
About the CFPB
- Loan Estimate
Mortgage Rules
- Closing Disclosure
- Service Providers
Released the Final Rule on
Integrated Disclosures November 20, 2013 at the CFPB
Field Hearing in Boston as part of
the “Know Before You Owe”
initiative.
- Delivery Alternatives
- QM / ATR
- - Three-DayDisclosures
Rule
Integrated
-Final Rule
All-In APR
-Loan Estimate
Electronic Storage
Refinance
- - Proposals Not
Closing Disclosure
Adopted
- Purchase – Buyer
- Purchase - Seller
Resources
Takeaways
What Lies Ahead?
Q&A
Stewart’s policy analyst talks
with CFPB Director, Richard
Cordray about Stewart’s effort to
provide education on the new
disclosures.
© Copyright Stewart 2014
11

12. CFPB Continues to Remedy Historic Closing Problems
Today’s Topics
- About the CFPB
-History of Disclosures
Effective Date
About the CFPB
- Loan Estimate
Mortgage Rules
Have you ever experienced one or more of the
following?
- Closing Disclosure
- Service Providers
- Delivery Alternatives
- QM / ATR
- - Three-DayDisclosures
Rule
Integrated
-Final Rule
All-In APR
-Loan Estimate
Electronic Storage
Refinance
- - Proposals Not
Closing Disclosure
Adopted
- Purchase – Buyer
Buyer and real estate professional have arrived at the title company
for closing
Buyer has no idea how much money they are responsible to bring
- Purchase - Seller
Resources
Takeaways
What Lies Ahead?
Q&A
Real estate professional is frustrated they have yet to receive a copy
of the HUD-1
Loan officer is saying the title company is responsible for the delay
Title company is saying they just received the loan package
When the consumer wins… we all win!
© Copyright Stewart 2014
12

13. Preview of things to come in 2014
Today’s Topics
- About the CFPB
-History of Disclosures
Effective Date
About the CFPB
- Loan Estimate
Mortgage Rules
- Closing Disclosure
- Service Providers
- Delivery Alternatives
- QM / ATR
CFPB Director Richard Cordray
Boston Field Hearing,
November 20, 2013
- - Three-DayDisclosures
Rule
Integrated
-Final Rule
All-In APR
-Loan Estimate
Electronic Storage
Refinance
- - Proposals Not
Closing Disclosure
Adopted
- Purchase – Buyer
- Purchase - Seller
Resources
Takeaways
What Lies Ahead?
Q&A
“So as part of our “Know Before You Owe” initiative, we are making a commitment
to work with industry to improve the mortgage closing experience for consumers
through technology. We believe that “eClosings” could represent a positive
development along these lines, and we want to know more about how we can
foster innovation in this area.
© Copyright Stewart 2014
13

14. Mortgage Rules
Today’s Topics
- About the CFPB
-History of Disclosures
Effective Date
About the CFPB
- Loan Estimate
Mortgage Rules
- Closing Disclosure
- Service Providers
- Delivery Alternatives
- QM / ATR
- - Three-DayDisclosures
Rule
Integrated
-Final Rule
All-In APR
-Loan Estimate
Electronic Storage
Refinance
- - Proposals Not
Closing Disclosure
Adopted
- Purchase – Buyer
- Purchase - Seller
Resources
Takeaways
Service Providers
What Lies Ahead?
Q&A
Qualified Mortgages
Integrated Disclosures
© Copyright Stewart 2014
14

15. Service Provider “flight to quality”
Today’s Topics
- About the CFPB
-History of Disclosures
Effective Date
About the CFPB
- Loan Estimate
Mortgage Rules
- Closing Disclosure
- Service Providers
- Delivery Alternatives
- QM / ATR
CFPB Bulletin to Banks and
Non-Banks stating they
must use quality service
providers.
- - Three-DayDisclosures
Rule
Integrated
-Final Rule
All-In APR
-Loan Estimate
Electronic Storage
Refinance
- - Proposals Not
Closing Disclosure
Adopted
- Purchase – Buyer
- Purchase - Seller
Resources
Takeaways
What Lies Ahead?
Q&A
© Copyright Stewart 2014
15

16. Qualified Mortgage / Ability-to-Repay
Today’s Topics
- About the CFPB
-History of Disclosures
Effective Date
About the CFPB
- Loan Estimate
Mortgage Rules
- Closing Disclosure
- Service Providers
- Delivery Alternatives
- QM / ATR
- - Three-DayDisclosures
Rule
Integrated
-Final Rule
All-In APR
-Loan Estimate
Electronic Storage
Refinance
- - Proposals Not
Closing Disclosure
Adopted
- Purchase – Buyer
- Purchase - Seller
Resources
Takeaways
What Lies Ahead?
Q&A
© Copyright Stewart 2014
16

17. CFPB Finalizes Rule on Integrated Disclosures
Today’s Topics
- About the CFPB
-History of Disclosures
Effective Date
About the CFPB
- Loan Estimate
Mortgage Rules
- Closing Disclosure
- Service Providers
- Delivery Alternatives
- QM / ATR
- - Three-DayDisclosures
Rule
Integrated
-Final Rule
All-In APR
-Loan Estimate
Electronic Storage
Refinance
- - Proposals Not
Closing Disclosure
Adopted
- Purchase – Buyer
- Purchase - Seller
Resources
Takeaways
Better Disclosures
What Lies Ahead?
Q&A
© Copyright Stewart 2014
17

18. Detailed Summary of the Final Rule
Today’s Topics
- About the CFPB
-History of Disclosures
Effective Date
About the CFPB
- Loan Estimate
Mortgage Rules
- Closing Disclosure
Detailed Summary – 7 pages
- Service Providers
Scope
- Delivery Alternatives
- QM / ATR
- - Three-DayDisclosures
Rule
Integrated
Loan Estimate
-Final Rule
All-In APR
-Loan Estimate
Electronic Storage
Closing Disclosure
Refinance
- - Proposals Not
Closing Disclosure
Adopted
- Purchase – Buyer
Limits on Cost Increases
- Purchase - Seller
Resources
Proposals Not Adopted
Takeaways
What Lies Ahead?
Effective Date
Q&A
*Final Rule – 1,888 pages
© Copyright Stewart 2014
18

19. Detailed Summary of the Final Rule
Today’s Topics
- About the CFPB
-History of Disclosures
Effective Date
1
Scope
a)
b)
c)
d)
Applications on or after 8/1/2015 fall under new rules
Closed-end loans only - No home equity lines
No reverse mortgages
No mobile home loans
Loan Estimate
a)
b)
c)
d)
e)
Replaces Good Faith Est. / Early Truth-in-Lending
Mortgage Broker may provide / Lender is still responsible
Delivery must be within 3 Business Days of ‘application’
Limitation on up-front fees with exception for credit reports
Disclaimer on early estimates used before Loan Estimate
Closing Disclosure
a)
b)
c)
d)
Replaces HUD-1 and Final Truth-in-Lending
Consumer must receive at least 3 business days before signing
APR changes over 1/8% require re-disclosure/ 3 Bus. Day wait
Escrow may prepare and/or deliver*
Limits on Increases
a) Items that generally cannot increase:
a) Creditor’s or broker’s charges for its own services
b) Charges for services provided by an affiliate
c) Charges where consumer is not permitted to shop
b) Other services can generally increase by 10% or less
Exceptions
a)
b)
c)
d)
Not Adopted
a) Re-defined “All In” APR
b) Storage in standard, electronic machine-readable format
c) Disclosure of Approximate Cost of Funds
About the CFPB
- Loan Estimate
Mortgage Rules
- Closing Disclosure
- Service Providers
- Delivery Alternatives
- QM / ATR
- - Three-DayDisclosures
Rule
Integrated
-Final Rule
All-In APR
2
-Loan Estimate
Electronic Storage
Refinance
- - Proposals Not
Closing Disclosure
Adopted
- Purchase – Buyer
- Purchase - Seller
3
Resources
Takeaways
What Lies Ahead?
Q&A
4
4a
5
Consumer requests the change
Consumer chooses their own service provider
Information at application is/becomes inaccurate
Loan Estimate expires
© Copyright Stewart 2014
19

20. CFPB Goals in Redesigning Forms
Today’s Topics
- About the CFPB
Help consumers by making all forms look similar
-History of Disclosures
Effective Date
About the CFPB
- Loan Estimate
Help consumers shop for best loan
Mortgage Rules
- Closing Disclosure
- Service Providers
- Delivery Alternatives
Help consumers guard against hikes in charges at closing
- QM / ATR
- - Three-DayDisclosures
Rule
Integrated
-Final Rule
All-In APR
-Loan Estimate
Electronic Storage
Refinance
- - Proposals Not
Help consumers understand future obligations
Good Faith Estimate
Truth in Lending
HUD-1
Closing Disclosure
Adopted
- Purchase – Buyer
- Purchase - Seller
Resources
Takeaways
What Lies Ahead?
Q&A
© Copyright Stewart 2014
20

21. Introducing the Forms
Today’s Topics
- About the CFPB
-History of Disclosures
Effective Date
About the CFPB
- Loan Estimate
Mortgage Rules
Today’s look at the samples provided by the Bureau
in the final rule announced November 20, 2013.
- Closing Disclosure
- Service Providers
- Delivery Alternatives
- QM / ATR
- - Three-DayDisclosures
Rule
Integrated
-Final Rule
All-In APR
-Loan Estimate
Electronic Storage
Refinance
- - Proposals Not
Closing Disclosure
Adopted
- Purchase – Buyer
- Purchase - Seller
Resources
Takeaways
What Lies Ahead?
Q&A
© Copyright Stewart 2014
21

22. How important are the new disclosures??
Today’s Topics
- About the CFPB
-History of Disclosures
Effective Date
About the CFPB
- Loan Estimate
Mortgage Rules
- Closing Disclosure
- Service Providers
- Delivery Alternatives
- QM / ATR
- - Three-DayDisclosures
Rule
Integrated
-Final Rule
All-In APR
-Loan Estimate
Electronic Storage
Refinance
- - Proposals Not
Closing Disclosure
Adopted
- Purchase – Buyer
- Purchase - Seller
Resources
Takeaways
What Lies Ahead?
Q&A
© Copyright Stewart 2014
22

23. Closing Disclosure for Purchase – Page 1
Closing Information
Today’s Topics
- About the CFPB
-History of Disclosures
Effective Date
Transaction Information
About the CFPB
- Loan Estimate
Mortgage Rules
Loan Information
- Closing Disclosure
- Service Providers
- Delivery Alternatives
- QM / ATR
Loan Terms
- - Three-DayDisclosures
Rule
Integrated
-Final Rule
All-In APR
Projected Payments
-Loan Estimate
Electronic Storage
Refinance
- - Proposals Not
Costs at Closing
Closing Disclosure
Adopted
- Purchase – Buyer
- Purchase - Seller
Resources
Takeaways
What Lies Ahead?
Q&A
© Copyright Stewart 2014
23

24. Closing Disclosure for Purchase – Page 1 - Detail
Today’s Topics
- About the CFPB
-History of Disclosures
Effective Date
About the CFPB
- Loan Estimate
Mortgage Rules
- Closing Disclosure
- Service Providers
- Delivery Alternatives
- QM / ATR
- - Three-DayDisclosures
Rule
Integrated
-Final Rule
All-In APR
-Loan Estimate
Electronic Storage
Refinance
- - Proposals Not
Closing Disclosure
Adopted
- Purchase – Buyer
- Purchase - Seller
Resources
Takeaways
What Lies Ahead?
Q&A
© Copyright Stewart 2014
24

25. Closing Disclosure for Purchase – Page 1 - Detail
Today’s Topics
- About the CFPB
-History of Disclosures
Effective Date
About the CFPB
- Loan Estimate
Mortgage Rules
- Closing Disclosure
- Service Providers
- Delivery Alternatives
- QM / ATR
- - Three-DayDisclosures
Rule
Integrated
-Final Rule
All-In APR
-Loan Estimate
Electronic Storage
Refinance
- - Proposals Not
Closing Disclosure
Adopted
- Purchase – Buyer
- Purchase - Seller
Resources
Takeaways
What Lies Ahead?
Q&A
© Copyright Stewart 2014
25

26. Closing Disclosure for Purchase – Page 2
Loan Costs
Today’s Topics
- About the CFPB
-History of Disclosures
Effective Date
Other Costs
About the CFPB
- Loan Estimate
Mortgage Rules
Total Costs
- Closing Disclosure
- Service Providers
- Delivery Alternatives
- QM / ATR
- - Three-DayDisclosures
Rule
Integrated
-Final Rule
All-In APR
-Loan Estimate
Electronic Storage
Refinance
- - Proposals Not
Closing Disclosure
Adopted
- Purchase – Buyer
- Purchase - Seller
Resources
Takeaways
What Lies Ahead?
Q&A
© Copyright Stewart 2014
26

27. Closing Disclosure for Purchase – Page 2 - Detail
Today’s Topics
- About the CFPB
-History of Disclosures
Effective Date
About the CFPB
- Loan Estimate
Mortgage Rules
- Closing Disclosure
- Service Providers
- Delivery Alternatives
- QM / ATR
- - Three-DayDisclosures
Rule
Integrated
-Final Rule
All-In APR
-Loan Estimate
Electronic Storage
Refinance
- - Proposals Not
Closing Disclosure
Adopted
- Purchase – Buyer
- Purchase - Seller
Resources
Takeaways
What Lies Ahead?
Q&A
© Copyright Stewart 2014
27

28. Closing Disclosure for Purchase – Page 2 - Detail
Today’s Topics
- About the CFPB
-History of Disclosures
Effective Date
About the CFPB
- Loan Estimate
Mortgage Rules
- Closing Disclosure
- Service Providers
- Delivery Alternatives
- QM / ATR
- - Three-DayDisclosures
Rule
Integrated
-Final Rule
All-In APR
-Loan Estimate
Electronic Storage
Refinance
- - Proposals Not
Closing Disclosure
Adopted
- Purchase – Buyer
- Purchase - Seller
Resources
Takeaways
What Lies Ahead?
Q&A
© Copyright Stewart 2014
28

29. Closing Disclosure for Purchase – Page 3
Cash-to-Close Calculations
Today’s Topics
- About the CFPB
-History of Disclosures
Effective Date
Transaction Summaries
About the CFPB
- Loan Estimate
Mortgage Rules
- Closing Disclosure
- Service Providers
- Delivery Alternatives
- QM / ATR
- - Three-DayDisclosures
Rule
Integrated
-Final Rule
All-In APR
-Loan Estimate
Electronic Storage
Refinance
- - Proposals Not
Closing Disclosure
Adopted
- Purchase – Buyer
- Purchase - Seller
Resources
Takeaways
What Lies Ahead?
Q&A
© Copyright Stewart 2014
29

30. Closing Disclosure for Purchase – Page 3 - Detail
Today’s Topics
- About the CFPB
-History of Disclosures
Effective Date
About the CFPB
- Loan Estimate
Mortgage Rules
- Closing Disclosure
- Service Providers
- Delivery Alternatives
- QM / ATR
- - Three-DayDisclosures
Rule
Integrated
-Final Rule
All-In APR
-Loan Estimate
Electronic Storage
Refinance
- - Proposals Not
Closing Disclosure
Adopted
- Purchase – Buyer
- Purchase - Seller
Resources
Takeaways
What Lies Ahead?
Q&A
© Copyright Stewart 2014
30

31. Closing Disclosure for Purchase – Page 3 - Detail
Today’s Topics
- About the CFPB
-History of Disclosures
Effective Date
About the CFPB
- Loan Estimate
Mortgage Rules
- Closing Disclosure
- Service Providers
- Delivery Alternatives
- QM / ATR
- - Three-DayDisclosures
Rule
Integrated
-Final Rule
All-In APR
-Loan Estimate
Electronic Storage
Refinance
- - Proposals Not
Closing Disclosure
Adopted
- Purchase – Buyer
- Purchase - Seller
Resources
Takeaways
What Lies Ahead?
Q&A
© Copyright Stewart 2014
31

32. Closing Disclosure for Purchase – Page 4
Loan Disclosures
Today’s Topics
- About the CFPB
-History of Disclosures
Effective Date
Escrow Account
About the CFPB
- Loan Estimate
Mortgage Rules
- Closing Disclosure
- Service Providers
- Delivery Alternatives
- QM / ATR
- - Three-DayDisclosures
Rule
Integrated
-Final Rule
All-In APR
-Loan Estimate
Electronic Storage
Refinance
- - Proposals Not
Closing Disclosure
Adopted
- Purchase – Buyer
- Purchase - Seller
Resources
Takeaways
What Lies Ahead?
Q&A
© Copyright Stewart 2014
32

33. Closing Disclosure for Purchase – Page 4 - Detail
Today’s Topics
- About the CFPB
-History of Disclosures
Effective Date
About the CFPB
- Loan Estimate
Mortgage Rules
- Closing Disclosure
- Service Providers
- Delivery Alternatives
- QM / ATR
- - Three-DayDisclosures
Rule
Integrated
-Final Rule
All-In APR
-Loan Estimate
Electronic Storage
Refinance
- - Proposals Not
Closing Disclosure
Adopted
- Purchase – Buyer
- Purchase - Seller
Resources
Takeaways
What Lies Ahead?
Q&A
© Copyright Stewart 2014
33

34. Closing Disclosure for Purchase – Page 5
Loan Calculations
Today’s Topics
- About the CFPB
-History of Disclosures
Effective Date
Other Disclosures
About the CFPB
- Loan Estimate
Mortgage Rules
Questions
- Closing Disclosure
- Service Providers
- Delivery Alternatives
- QM / ATR
Contact Information
- - Three-DayDisclosures
Rule
Integrated
-Final Rule
All-In APR
Confirmation of Receipt
-Loan Estimate
Electronic Storage
Refinance
- - Proposals Not
Closing Disclosure
Adopted
- Purchase – Buyer
- Purchase - Seller
Resources
Takeaways
What Lies Ahead?
Q&A
© Copyright Stewart 2014
34

35. Closing Disclosure for Purchase – Page 5
Today’s Topics
- About the CFPB
-History of Disclosures
Effective Date
About the CFPB
- Loan Estimate
Mortgage Rules
- Closing Disclosure
- Service Providers
- Delivery Alternatives
- QM / ATR
- - Three-DayDisclosures
Rule
Integrated
-Final Rule
All-In APR
-Loan Estimate
Electronic Storage
Refinance
- - Proposals Not
Closing Disclosure
Adopted
- Purchase – Buyer
- Purchase - Seller
Resources
Takeaways
What Lies Ahead?
Q&A
© Copyright Stewart 2014
35

36. Closing Disclosure for Purchase – Page 5
Today’s Topics
- About the CFPB
-History of Disclosures
Effective Date
About the CFPB
- Loan Estimate
Mortgage Rules
- Closing Disclosure
- Service Providers
- Delivery Alternatives
- QM / ATR
- - Three-DayDisclosures
Rule
Integrated
-Final Rule
All-In APR
-Loan Estimate
Electronic Storage
Refinance
- - Proposals Not
Closing Disclosure
Adopted
- Purchase – Buyer
- Purchase - Seller
Resources
Takeaways
What Lies Ahead?
Q&A
© Copyright Stewart 2014
36

37. Closing Disclosure for Seller Only – Page 1
Closing Information
Today’s Topics
- About the CFPB
-History of Disclosures
Effective Date
Transaction Information
About the CFPB
- Loan Estimate
Mortgage Rules
Summaries of Transactions
- Closing Disclosure
- Service Providers
- Delivery Alternatives
- QM / ATR
Contact Information
- - Three-DayDisclosures
Rule
Integrated
-Final Rule
All-In APR
-Loan Estimate
Electronic Storage
Refinance
- - Proposals Not
Closing Disclosure
Adopted
- Purchase – Buyer
- Purchase - Seller
Resources
Takeaways
What Lies Ahead?
Q&A
© Copyright Stewart 2014
37

38. Closing Disclosure for Seller Only – Page 1 - Detail
Today’s Topics
- About the CFPB
-History of Disclosures
Effective Date
About the CFPB
- Loan Estimate
Mortgage Rules
- Closing Disclosure
- Service Providers
- Delivery Alternatives
- QM / ATR
- - Three-DayDisclosures
Rule
Integrated
-Final Rule
All-In APR
-Loan Estimate
Electronic Storage
Refinance
- - Proposals Not
Closing Disclosure
Adopted
- Purchase – Buyer
- Purchase - Seller
Resources
Takeaways
What Lies Ahead?
Q&A
© Copyright Stewart 2014
38

39. Closing Disclosure for Seller Only – Page 1 - Detail
Today’s Topics
- About the CFPB
-History of Disclosures
Effective Date
About the CFPB
- Loan Estimate
Mortgage Rules
- Closing Disclosure
- Service Providers
- Delivery Alternatives
- QM / ATR
- - Three-DayDisclosures
Rule
Integrated
-Final Rule
All-In APR
-Loan Estimate
Electronic Storage
Refinance
- - Proposals Not
Closing Disclosure
Adopted
- Purchase – Buyer
- Purchase - Seller
Resources
Takeaways
What Lies Ahead?
Q&A
© Copyright Stewart 2014
39

40. Closing Disclosure for Seller Only – Page 2
Closing Cost Details
Today’s Topics
- About the CFPB
-History of Disclosures
Effective Date
Loan Costs
About the CFPB
- Loan Estimate
Mortgage Rules
Other Costs
- Closing Disclosure
- Service Providers
- Delivery Alternatives
- QM / ATR
- - Three-DayDisclosures
Rule
Integrated
-Final Rule
All-In APR
-Loan Estimate
Electronic Storage
Refinance
- - Proposals Not
Closing Disclosure
Adopted
- Purchase – Buyer
- Purchase - Seller
Resources
Takeaways
What Lies Ahead?
Q&A
© Copyright Stewart 2014
40

41. Closing Disclosure for Seller Only – Page 2 - Detail
Today’s Topics
- About the CFPB
-History of Disclosures
Effective Date
About the CFPB
- Loan Estimate
Mortgage Rules
- Closing Disclosure
- Service Providers
- Delivery Alternatives
- QM / ATR
- - Three-DayDisclosures
Rule
Integrated
-Final Rule
All-In APR
-Loan Estimate
Electronic Storage
Refinance
- - Proposals Not
Closing Disclosure
Adopted
- Purchase – Buyer
- Purchase - Seller
Resources
Takeaways
What Lies Ahead?
Q&A
© Copyright Stewart 2014
41

42. Closing Disclosure for Seller Only – Page 2 - Detail
Today’s Topics
- About the CFPB
-History of Disclosures
Effective Date
About the CFPB
- Loan Estimate
Mortgage Rules
- Closing Disclosure
- Service Providers
- Delivery Alternatives
- QM / ATR
- - Three-DayDisclosures
Rule
Integrated
-Final Rule
All-In APR
-Loan Estimate
Electronic Storage
Refinance
- - Proposals Not
Closing Disclosure
Adopted
- Purchase – Buyer
- Purchase - Seller
Resources
Takeaways
What Lies Ahead?
Q&A
© Copyright Stewart 2014
42

43. Resources
Today’s Topics
- About the CFPB
-History of Disclosures
Effective Date
About the CFPB
- Loan Estimate
Mortgage Rules
stewart.com/cfpb
Service Provider Memo
- Closing Disclosure
- Service Providers
- Delivery Alternatives
- QM / ATR
- - Three-DayDisclosures
Rule
Integrated
-Final Rule
All-In APR
-Loan Estimate
Electronic Storage
Refinance
- - Proposals Not
Closing Disclosure
Adopted
- Purchase – Buyer
- Purchase - Seller
Resources
Takeaways
What Lies Ahead?
Q&A
ALTA Best Practices
QM / ATR
Integrated Disclosures
Loan Estimate
Closing Disclosure
Realtor info
Lender info
Homebuyer education
© Copyright Stewart 2014
43

44. Takeaways
Today’s Topics
- About the CFPB
-History of Disclosures
Effective Date
About the CFPB
- Loan Estimate
Mortgage Rules
- Closing Disclosure
- Service Providers
- Delivery Alternatives
- QM / ATR
- - Three-DayDisclosures
Rule
Integrated
-Final Rule
All-In APR
-Loan Estimate
Electronic Storage
Refinance
- - Proposals Not
Closing Disclosure
Adopted
- Purchase – Buyer
- Purchase - Seller
Resources
Takeaways
What Lies Ahead?
Q&A
Be Proactive
Discuss the issues
Identify process changes
Plan for the 3-Day Rule
Print the new forms from stewart.com/cfpb
Practice with your team
Invite your compliance officer to join us
Partner with Stewart
© Copyright Stewart 2014
44

45. What lies ahead?
Today’s Topics
- About the CFPB
-History of Disclosures
Effective Date
About the CFPB
- Loan Estimate
Mortgage Rules
- Closing Disclosure
- Service Providers
- Delivery Alternatives
- QM / ATR
- - Three-DayDisclosures
Rule
Integrated
-Final Rule
All-In APR
-Loan Estimate
Electronic Storage
Refinance
- - Proposals Not
Closing Disclosure
Adopted
- Purchase – Buyer
- Purchase - Seller
Resources
Takeaways
What Lies Ahead?
Q&A
© Copyright Stewart 2014
45

46. Questions?
Today’s Topics
- About the CFPB
-History of Disclosures
Effective Date
About the CFPB
- Loan Estimate
Mortgage Rules
- Closing Disclosure
- Service Providers
- Delivery Alternatives
- QM / ATR
- - Three-DayDisclosures
Rule
Integrated
-Final Rule
All-In APR
-Loan Estimate
Electronic Storage
Refinance
- - Proposals Not
Closing Disclosure
Adopted
- Purchase – Buyer
- Purchase - Seller
Resources
Takeaways
What Lies Ahead?
Q&A
Q&A
© Copyright Stewart 2014
46

47. Today’s Topics
- About the CFPB
-History of Disclosures
Effective Date
About the CFPB
- Loan Estimate
Mortgage Rules
- Closing Disclosure
- Service Providers
- Delivery Alternatives
- QM / ATR
- - Three-DayDisclosures
Rule
Integrated
-Final Rule
All-In APR
-Loan Estimate
Electronic Storage
Refinance
- - Proposals Not
Closing Disclosure
Adopted
- Purchase – Buyer
- Purchase - Seller
Resources
Takeaways
What Lies Ahead?
Q&A
Thank You!
© Copyright Stewart 2014
47