The TILA or Truth In Lending Act of 2009 dramatically alters the rules that lenders must follow during the application and disclosure process of originating loans.  The new rules for the TILA amended disclosure requirements, sets waiting periods and institutes fee disclosure requirements that are even more strict then they have been in the past.

Lenders will not be able to close a loan until 7 business days following the mailing or delivery of the initial disclosures.   Also, if the Annual Percentage Rate that has been mailed/delivered changes by more or less than .125% or $100 then the lender is required to re-disclose or provide the borrower with corrected initial disclosures no later than 3 business days prior to the closing.  There is a option to waive these waiting periods but you have to prove a valid emergency so it is very likely that will be a vast exception to the rule.  Saturday is now included as a “business” day where previously it was not.  Sunday is the only non-business day now.

Also lenders will not be able to collect any fees upfront until after the signed TIL is received or after a 3 day waiting period. This has never been an issue because we don’t ever charge upfront fees anyway.

For VA home owners and those who wish to get a new VA loan it will affect you in one way more than anything – waiting.  For some reason the Fed believes that apparently loans are being closed too fast and people aren’t able to make decisions in what I feel is a regular amount of time on their refinance.  I believe it may also help those persons who maybe aren’t as familiar with the refinance process and become even more educated.