3 Day Disclosures
The Consumer Financial Protection Bureau has implemented a new rule requiring disclosure of HOA costs and fees in 3 business days. This includes CIC documents, transfer/record change fees, status letter fees, assessments
To comply with this 3 day requirement, title companies are expected to request HOA information and figures at least 3 weeks prior to closing. HOA management companies and self-managed HOAs should expect an influx of urgent inquiries for timely disclosure.
This new federal rule is also in the CAM rules, adopted this year. By state statute, HOAs had 14 calendar days to provide a status letter. That statutory timeframe is now collapsed by the federal and state rules.
HOA management companies and HOAs should implement procedures to ensure compliance with these new deadlines.
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