Using Old vs New GFE, TIL, HUD

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Question:

If the old GFE, TIL and HUD were used prior to changes, do the old forms need to be used now going to a final const/perm end loan? (We need to redisclose.)

Answer:

All RESPA disclosures provided on 1/1/10 or after must be on the new forms. The new RESPA disclosure requirements were based on when they were given, not when the application was received.

Clarification: If the old GFE was provided prior to 1/1/10, and no new GFE is required to be issued on or after 1/1/10, then you would close the loan using the old HUD format.

First published on BankersOnline.com 3/28/11