That is the most frequently asked question among title and settlement agent regarding the August 1, 2015 implementation date for Integrated Mortgage Closing Disclosure Form (CDF). Can a lender/creditor require a settlement agent to use the form prior to August 1, 2015? The CFPB addressed this question their Compliance Guide.
Can a creditor use the new Integrated Disclosures for applications received before August 1, 2015?
No. For transactions where the application is received prior to August 1, 2015, creditors will still need to follow the current disclosure requirements under Regulations X and Z, and use the existing forms (Truth-in-Lending disclosures, GFE, HUD-1).
To view the entire Compliance Guide click below:
http://www.consumerfinance.gov/f/201409_cfpb_tila-respa-integrated-disclosure-rule_compliance-guide.pdf