Beginning this fall, the process for closing a home will become very different. Citibank is implementing the transition for the RESPA/TILA Harmonization, which will be a process of combining the Real Estate Procedures Act (RESPA) with the Truth in Lending Act (TILA). This will also be known as the Know Before You Owe rule. Originally, this implementation was to begin in August, but has been pushed back to October.
As a result, starting October 3rd, 2015, Citibank will change the terms of their Closing Disclosure to contact the borrower three (3) business days before the loan closing.
Changes like this might seem particularly daunting for a borrower, but it’s important to stay aware of them as they occur. Here is a brief rundown of the effects that will be taking place after October 3rd:
• Citibank will be contacting borrowers twelve (12) days prior to the closing date to obtain final fees.
• Once this is obtained, Citibank will then send the borrower an Initial Closing Disclosure (ICD) for your review and approval.
• Information required for the ICD will include contact information, including legal name, address, license number, contact name, email address, and phone number. Additionally, Citibank might also require borrowers to obtain contact information for the realtors involved in this transaction.
• After your approval, Citibank will then mail the ICD to the borrow six (6) days prior to the scheduled closing date.
• Once the ICD has been presented and approved, at the closing table the ICD document will then be referred to as the Closing Disclosure (CD). This final CD will be mailed by Citibank to the borrowers for execution.
• Citibank also expects borrowers to notify the Citi Closer immediately if there are any changes that will impact the ICD, as this will guarantee that Citibank has enough time to determine if those changes require a revised CD to be provided at closing, or if the changes are so extensive that the three-day waiting period will be triggered once more and a new closing date will need to be scheduled.
Now, because this process is so finite and time-sensitive, you don’t want to miss out on any steps with the new disclosures. If you have any questions about your process, Two Rivers Title can assist you. Two Rivers Title is ALTA Best Practices Compliant.
If you are planning to buy or sell a home after October of this year, let Two Rivers Title help you from start to finish.
For the full information on the RESPA/TILA Humanization changes, and Citibank’s new requirements and important dates, the full press release is here.
And this is the information indicating that the implementation date has been changed for the Know Before You Owe rule here.