FHLBC - MPF in Focus

Keep Your TILA-RESPA Preparation in Motion

The Consumer Financial Protection Bureau (CFPB) issued a new effective date for the TILA-RESPA Integrated Disclosure Rule, the “Know Before You Owe” Rule, pushing the original date of Saturday, August 1, 2

015 to Saturday, October 3, 2015.

Take advantage of this extension to thoroughly evaluate the impact of this rule as you prepare your institution for compliance.

During your preparations, has your institution considered the following:

Have you tested new processes, procedures, or systems?
Have you trained your staff to comply with the Rule?
Have you considered how you will use the new Your Home Loan Toolkit that is replacing the Settlement Cost Booklet?
Have you contacted your vendors to ensure they will be ready to comply?
Have you developed a strategy for coordinating and communicating with all parties involved in a mortgage loan transaction (i.e. the buyer, seller, loan officer, real estate agent, title company, and settlement agent)?
Have you consulted with your legal counsel and/or compliance team?
Have you developed an alternative plan of action if you or your vendors are not ready by the effective date of the Rule?
Have you created a strategy to monitor your institution and your vendors’ continued compliance with the Rule even after the implementation date?

It is important to note that if your institution is out of compliance with applicable laws, including the Rule, the MPF Program will not purchase any loans from your institution while it remains out of compliance. Additionally, any loans delivered under the MPF Program that do not comply with applicable laws are subject to repurchase.

Resources

MPF University
The MPF Program is offering the free online audio courses below through MPF University to introduce PFIs to the integrated disclosure forms. PFIs may register for these courses at MPF University under Available Courses. The courses are accessed with the Audio On-Demand link.

RESPA-TILA - The Closing Disclosure
RESPA-TILA - The Loan Estimate
Highlights of the TILA/RESPA Disclosure Integration Rule

CFPB
The CFPB has a designated “TILA-RESPA Integrated Disclosure Rule Implementation” page on its website, which provides guidance material and a series of webinars. The webinars can be accessed by following the links below:

The preceding general discussions of the Rule do not constitute and are not intended to be relied on by PFIs as legal advice with respect to the Rule or its applicability. Each PFI is expected to consult with its own counsel for advice concerning the Rule and its applicability.

If you have any questions or concerns about your institution being ready to comply with the Rule, please contact your MPF Bank Representative immediately.

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FHLBC 200 East Randolph Drive Chicago, IL 60601 Phone: (877) 463-6673 www.fhlbmpf.com	New loan purchases available through the Federal Home Loan Banks of Atlanta, Boston, Chicago, Dallas, Des Moines, New York, Pittsburgh, San Francisco, and Topeka.
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This newsletter contains forward-looking statements which are based upon our current expectations and speak only as of the date hereof. These statements may use forward-looking terms, such as “anticipates”, “believes”, “expects”, “could”, “plans”, “estimates”, “may”, “should”, “will,” or their negatives or other variations on these terms.We caution that, by their nature, forward-looking statements involve risk or uncertainty, that actual results could differ materially from those expressed or implied in these forward-looking statements, and that actual events could affect the extent to which a particular objective, projection, estimate, or prediction is realized. These forward-looking statements involve risks and uncertainties including, but not limited to, the risk factors set forth in our periodic filings with the Securities and Exchange Commission, which are available on our website at www.fhlbc.com. We assume no obligation to update any forward-looking statements made in this newsletter.