On Wednesday, December 18, 2019, the Consumer Financial Protection Bureau (CFPB) published two guidance documents related to disclosing construction and construction-permanent loans under the TILA-RESPA Integrated Disclosure (TRID) Rule using the Loan Estimate and Closing Disclosure forms. One guide addresses a combined, one-transaction disclosure construction-to-permanent loan. The other provides guidance on disclosing a construction-to-permanent loan using separate disclosures for each phase (construction and permanent).
In addition, the guides provide guidance and illustrative examples for commonly asked TRID and Regulation Z provisions related to completing the construction and construction-permanent loan disclosures. No new regulations were created; rather, the CFPB has issued these guides for financial institutions to provide clarity on disclosing construction-to-permanent loans with demonstrative examples.
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