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#2017001 - 05/29/15 04:41 PM Integrated Disclosure Rule
Dlynn58 Offline
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Joined: Mar 2006
Posts: 788
Texas
I have a question about the integrated disclosure rule. Our bank does not do any owner occupied mortgage loans. However, we do construction only loans and loans secured by 25 or more acres. My question is according CFPB’s guide, the new rule doesn’t apply to loans made by an entity that makes five or fewer mortgages in a calendar year. What is the definition of a mortgage loan, for this rule. Because we do not make any “mortgage owner occupied loans” does this exempt us from the rule? Or, does this rule apply and we need to give out the new integrated disclosures on any commercial construction loans or land purchases?

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TRID - TILA/RESPA Integrated Disclosures Rule
#2017007 - 05/29/15 04:52 PM Re: Integrated Disclosure Rule Dlynn58
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 80,390
Galveston, TX
Coverage of the TILA has not changed. Read the commentary to Paragraph 2(a)(17)(i). The two prong test is still the same. Unless you make a total of less than 25 consumer loans a year, your bank is covered regardless of how many mortgage loans you do.
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#2017011 - 05/29/15 04:59 PM Re: Integrated Disclosure Rule Dlynn58
Dlynn58 Offline
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Joined: Mar 2006
Posts: 788
Texas
Thanks Randy!

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#2017039 - 05/29/15 05:54 PM Re: Integrated Disclosure Rule Dlynn58
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
Joined: Dec 2000
Posts: 21,292
And I confirmed this with the CFPB. The rule is as stated in the reg and commentary. When the CFPB states the five or fewer rule, they are essentially assuming a creditor that does no other consumer lending.
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Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy
www.kaybeescomplianceinsights.com

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#2017152 - 05/29/15 08:46 PM Re: Integrated Disclosure Rule Dlynn58
RVFlyboy Offline
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RVFlyboy
Joined: Oct 2000
Posts: 5,985
Soaring over Georgia
Kathleen, they seem to have a habit of assuming quite a bit. Like assuming all our LOS vendors are going to be ready by 8/1. Someone should clue them in on what happens when you assume.
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#2017201 - 05/30/15 02:11 AM Re: Integrated Disclosure Rule Dlynn58
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
Joined: Dec 2000
Posts: 21,292
True. They do discuss the trigger in the preamble and say "no change" so I really don't understand why they keep spouting about five or fewer.
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Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy
www.kaybeescomplianceinsights.com

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