Changes to Regulation Z-Mortgage Disclosure Improvement Act (MDIA) By: Fran Sponsler, CRCM and Melissa Good Date: 7/30/09 Regulation Z changes regarding disclosure requirements, waiting periods and fees will go into effect July 30, 2009.  Under the revised regulation, initial or early disclosures must be provided to all consumer loans secured by a 1-4 family dwelling including home refinance loans, home equity loans, and loans to finance the purchase or construction of the consumer’s primary residence.  One notable exception to this new disclosure rule is for home equity lines of credit, which are not included.  All disclosures must contain the verbiage “You are not required to complete this agreement merely because you have received these disclosures or signed a loan application.” A creditor will not be able to close a loan until seven business days following the mailing or delivery of the initial disclosures.  A business day under this rule is defined as “all calendar days except Sundays and the (ten) Federal holidays specified in 5 U.S.C. 6103(a).  If the Annual Percentage Rate shown in the initial disclosures becomes inaccurate (out of tolerance), the creditor is required to re-disclose or provide the borrower with corrected initial disclosures no later than three business days prior to the closing. Fees may not be collected from a borrower prior to the disclosures being provided, with the exception of fees to obtain credit history reports.  The scope of this rule has been expanded to include mortgages secured by dwellings other than the borrower’s primary residence, including second or vacation homes. Finally, regarding timeshare transactions, creditors are required to provide the early or initial disclosures to borrowers within the normal three-day RESPA timeframe.  In other words, the additional three- or seven-day period does not apply to these transactions.  However, the creditor must ensure the disclosure provided at consummation is accurate within the specified tolerances.