Credit Sales and Integrated Disclosures

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Question:

Prior to Integrated Disclosures, a credit sale (selling and financing an OREO property) required us to disclose the Total Sale Price on an Estimated and Final TIL (12 CFR 1026.18(j)). Is there a similar requirement on the new Loan Estimate and/or Closing Disclosure or has this gone by the wayside?

Answer:

Review Comment 18-3.i. to see why this and other section 1026.18 requirements don't apply to loans that are subject to the TRID rules:

3. Scope of coverage. i. Section 1026.18 applies to closed-end consumer credit transactions, other than transactions that are subject to § 1026.19(e) and (f). Section 1026.19(e) and (f) applies to closed-end consumer credit transactions that are secured by real property, other than reverse mortgages subject to § 1026.33. Accordingly, the disclosures required by § 1026.18 apply only to closed-end consumer credit transactions that are:

A. Unsecured;

B. Secured by personal property that is not a dwelling;

C. Secured by personal property that is a dwelling and is not also secured by real property; or

D. Reverse mortgages subject to § 1026.33.