State Regulatory Developments

Vermont Revises Mortgage Commitment Letter Requirements

The Vermont DFR made revisions to the content and timing requirements of mortgage commitment letters; the new requirements are effective October 1, 2018.

The revised rules allow lenders to create two additional types of mortgage commitment letters: (1) a short form commitment letter; and (2) a reverse mortgage commitment letter.  However, the mortgage commitment letter and the reverse mortgage commitment letter must now include the name and phone number of the licensed or registered mortgage loan originator as well as the NMLS identification number for both the lender and the mortgage loan originator.  The short form commitment letter does not share this requirement, but it must be delivered to the borrower concurrently with the Closing Disclosure.  The revised rules also require the mortgage commitment letter and the reverse mortgage commitment letter to disclose various fees based on the lender’s requirements under Regulation X.  Additionally, the revised rules generally require the commitment letters to be delivered to the borrower no less than three business days prior to closing.