There are a few updates/clarifications released by the CFPB on January 18th, 2015 regarding the TILA/RESPA integrated disclosure rule also known as TRID -yes, I know, one more acronym to learn!
1. Originally, a lender was required to issue a loan estimate on the day that a loan status went from floating to locked. As you can imagine that didn’t set very well with operations because that turn time was way too tight to accomplish. So, the CFPB changed the regulation to allow for the normal 3 days.
2. The second change refers to New Construction properties and in particular, those loans which are expected to consummate (read close) 60 days or more after the initial loan estimate. Which, of course, is many new construction loans. The lender is permitted to issue another loan estimate within 60 days of the consummation provided that they inform the client of this on the original loan estimate. The problem was, there was no place to put this disclosure on the statement. Now, you can add it to the “other considerations” section.
3. Finally, Amended the 2013 Loan Originator Final Rule to include that the Name and NMLSR ID be included on the new TILA/RESPA disclosures.
If you are in charge of this for your company or you have trouble sleeping at night, I’ve included the document below for your reference. CLICK HERE!
