Vermont Banking Division Amends Commitment Letter Requirements for Mortgage Loans

The Vermont Banking Division (Division) adopted rules amending commitment letter requirements with respect to mortgage loans. Per the adopted rules, the Division: amended the content that must be set forth in a commitment letter; revised the timing of a commitment letter (must now be delivered at least 3 business days prior to closing rather than 24 hours prior to closing); clarified requirements with respect to a borrower’s waiver or modification of the 3 business day waiting period, in the event of a personal financial emergency; and now permits lenders to provide a short form of the commitment letter when the lender is required to issue a Closing Disclosure pursuant to the Federal Truth-in-Lending Act. The Division also added several definitions, including definitions for “residential real estate” and “dwelling.” Under the new definitions, the Division’s commitment letter requirements apply to 1-to 4-family property located in Vermont (including an individual condominium unit, cooperative unit, mobile home and trailer, if used as a residence). The bill becomes effective October 1, 2018.

See Vermont State Legislature website for the full text of the Statutes:
http://www.dfr.vermont.gov/sites/default/files/dfr-regulation-banking-b-2018-02-commitment-letter.pdf

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