Integrated Disclosures - An Implementation Strategy


Presented by: Mary Beth Guard and Jack Holzknecht

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Dodd-Frank Act revisions require that mortgage disclosures required by the Truth in Lending Act and the Real Estate Settlement Procedures Act be combined into a single disclosure. Final rules amending Regulation Z were published on November 20, 2013. Those rules are effective on August 1, 2015.

The new Loan Estimate, which combines the old early Truth in Lending disclosure with a Good Faith Estimate, generally must be delivered no later than the third business after application. The new Closing Disclosure, which combines the old final Truth in Lending disclosure with a HUD-1 or HUD-1A Settlement Statement, generally must received by the consumer three business days before consummation.

The new disclosures must be provided for transaction if the application is received on or after August 1, 2015. For applications received before August 1 old disclosures are used even when the transaction will close on or after August 1.

The Integrated Disclosures must be provided in a closed-end consumer credit transaction secured by a real property, whether there is a dwelling or not. The revised rules apply to any consumer purpose transaction , including purchase, refinance , second mortgages, and more. Construction loans and other temporary financing situations now receive disclosures.

The changes also impact various third parties involved in your mortgage origination process. Obviously your loan originator software (LOS) provider will play a major role in the implementation process. You need assurances now from your LOS provider regarding the delivery date of their updated product. The new rules will also significantly impact your settlement service providers.

These rules and many others require major revisions to your policies and procedures and other elements of your compliance management system. Determine which products and which departments are impacted by the changes. Begin the process of developing and implementing revised procedures.

Training is best conducted in stages. The first phase should introduce those who will be working with the new disclosures to the basic concepts of covered transactions, timing of disclosures and an overview of the content of the new disclosures. More specific training will follow later on specific content rules, special disclosure situations, and curing violations.

It appears that some financial institutions are waiting to receive updated loan origination software to begin implementation efforts. There is much work that can and should be completed before that event takes place. The compliance management system, vendor issues and initial training all need attention in the near future.

Upon completion of the program participants will have a plan for:
  • Informing the Board and Senior Management of the changes and involving them in the implementation process;
  • Revising Policies and Procedures;
  • What loans are covered and what loans are exempt from the new rules;
  • When are the rules effective;
  • Basic content of the new Loan Estimate and the new Closing Disclosure;
  • Managing Third Party Vendors, including
  • Loan originator software providers;
  • Settlement service Providers;
  • Training everyone involved in implementing the changes and those who will be using the new disclosures; and
  • Auditing for compliance with the new rules.
The program is designed for compliance officers, management of mortgage loan departments, auditors and others involved in implementing the changes and in originating consumer loans secured by real property.

About the Speakers: Jack Holzknecht is a principal with Pegasus Educational Services, LLC. He has been delivering the word on lending compliance for 38 years. In 33 years as a trainer over 125,000 bankers (and many examiners) have participated in Jack's live seminars and webinars. Jack's career began in 1976 as a federal bank examiner. He later headed the form, software and education divisions of a regional consulting company. There he developed loan and deposit form systems and software. He also developed and presented training programs to bankers in 43 states. Jack has been an instructor at compliance schools presented by several state bankers associations. He developed and delivered compliance training for the FDIC for ten years. Jack is a Certified Regulatory Compliance Manager and a member of the National Speakers Association. He is also a BOL Guru.

Mary Beth Guard currently serves as Executive Editor of, CEO of Glia Group, Inc. and Executive Editor of Since graduating from law school in 1980, Mary Beth has focused her work almost exclusively on the banking industry. Previously, Mary Beth served as EVP/General Counsel and COO for the Oklahoma Bankers Association, EVP of Specialized Services for Thomson Financial Publishing, and General Counsel for the Oklahoma State Banking Department. Mary Beth is on the advisory board for Bankers' Hotline. She has presented training programs for virtually every major national financial industry association, as well as more than a dozen state bankers associations and a host of other organizations. In addition, Mary Beth has written more than a thousand banking-related articles and is a BOL Guru.

This program was recorded in its entirety in December 2014. The CD-ROM includes program slides, materials (if available) and follow-up Q & A document.

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  • Model: cd_intdisclosure1214
  • Manufactured by: Glia Group, Inc.

This product was added to our catalog on Monday 10 November, 2014.

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