The Consumer Financial Protection Bureau has added five new questions and answers related to Housing Assistance Loans to the TILA-RESPA Integrated Disclosure FAQs. The new questions, which are effective immediately, cover:
- Are housing assistance loans covered by the TRID rule?
- What are the criteria for the Regulation Z Partial exemption from the Loan Estimate and Closing Disclosure Requirements?
- What are the criteria for the BUILD Act Partial Exemption from the Loan Estimate and Closing Disclosure Requirements?
- If a creditor opts for one of the artial exemptions, from which disclosure requirements is the transaction exempt?
- Can a creditor provide the Loan Estimate and Closing Disclosure for a loan that qualifies for the BUILD Act Partial Exemption?
This series of questions revolve around the issue of the Regulation Z Partial Exemption. Eligibility requirements for the Partial Exemption include, but are not limited to, a credit contract that:
- Does not require the payment of interest; and
- Provides that repayment of the amount of credit extended is forgiven either incrementally or in whole.
Needless to say, typical loan terms do not include these provisions.