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What is the difference between a Truth-in-Lending Disclosure and Closing Disclosure?

A Truth in Lending Disclosure (TIL) and a Lender Closing Disclosure (CD) are both required by federal law and are intended to provide borrowers with important information about the terms and costs of a mortgage loan. However, the TIL is provided early in the loan process and the CD is provided just before the loan closes.

The Truth in Lending Disclosure is required by the Truth in Lending Act (TILA) and must be provided to the borrower no later than three days after the consumer applies for the loan. This is usually triggered when a property address is added to the loan application. The TIL disclosure provides the borrower with information about the Annual Percentage Rate (APR) of the loan, which expresses the cost of credit and includes the interest rate and other charges, such as points, origination fees, and mortgage insurance. The TIL also includes information about the finance charge and the total of payments. Think of the TIL a an initial estimate of a loan and its associated costs.

The Lender Closing Disclosure is required by the Real Estate Settlement Procedures Act (RESPA) and must be provided to the borrower at least three days before the closing of the loan. The CD provides the borrower with a detailed breakdown of all the costs associated with the loan, including the loan origination fee, title search and insurance, recording fees, and any other charges. The CD also includes information about the loan terms, such as the interest rate, the monthly payments and the total amount of the loan. Think of the CD as the actual cost of a loan and it's associated costs.

In summary, the TIL provides the borrower with an early estimate of the cost of credit, while the CD provides a detailed breakdown of all the costs associated with the loan and the loan terms, right before the loan closing.

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