Today, the CFPB announced the publication of additional “TILA-RESPA Integrated Disclosure FAQs” on their website, specifically addressing the partial exemptions extended by the “Building Up Independent Lives and Dreams” (BUILD) Act (134 Stat. 5134 ) to the TILA-RESPA Integrated Disclosure rules. This Act created 12 U.S.C.A. § 2603(d) and 15 U.S.C.A. §§ 1604(e), which provides certain exemptions to loans:
- Which have a zero percent interest rate;
- In which only bona fide and reasonable fees are charged;
- Which are primarily for a charitable purpose; and
- Which involve a 501(c) organization.
We are currently reviewing this announcement to determine any impact, and evaluating any modifications, to our document library and/or systems. Any modifications we make as a result will be announced on our website (https://compliance.docutech.com/).