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TRID (TILA-RESPA Integrated Disclosures) was implemented October 1, 2015.  However, like all new regulations, there are always clarifications and technical issues that need to be addressed based on the feedback from those having to implement the rule.  The TRID rule was comprehensive, changed the way we disclose to consumers and quite confusing when first implemented.  There were many procedural questions and technical issues left unanswered, and as a result exposed lenders to possible litigation by consumers or fines for non-compliance with the rule.  With this release, the CFPB seeks to clarify the biggest issues lenders have faced.

Interpretive Comments:

This release is over 560 pages, so we have not had the time to dissect the document completely.  Future postings will address this document in deeper detail.  What we do know now are the main issues addressed by the CFPB to assist lenders in implementing the clarified procedures.  The rule will be effective 60 days after the publication in the Federal Register but will be mandatory for all lenders for applications dated October 1, 2018, or after.  This will allow enough time for lenders and their vendor partners to change processes that will accommodate the clarifications.

I’m attaching the Final Rule Below just in case you want to read along with me!

Clarifications Have Been Issued for:

  • Affiliate charges
  • Calculating cash-to-close table
  • Construction loans
  • Decimal places and rounding
  • Escrow account disclosures
  • Escrow cancellation notices
  • Expiration dates for the closing costs disclosed on the Loan Estimate
  • Gift funds
  • The “In 5 Years” calculation
  • Lender and Seller credits
  • Lenders’ and settlement agents’ respective responsibilities
  • The list of service providers
  • Non-obligor consumers
  • Partial payment policy disclosures
  • Payment ranges on the projected payments table
  • The payoffs and payments table
  • Payoffs with a purchase loan
  • Post consummation fees
  • Principal reduction (principal curtailment)
  • Disclosure and good-faith determination of property taxes and property value
  • Rate locks
  • Recording fees
  • Simultaneous second-lien loans
  • The summaries of transactions table
  • The total interest percentage calculation
  • Trusts
  • Informational updates to the Loan Estimate

There will be further attention given to the clarifications within the rule in future postings.

As a reminder, we will begin to dissect the 560 pages, talk with legal experts and get you the information you need to know so stay tuned!

CFPB  Final Rule Amendments -TILA

Tammy Butler, Master CMB

Author Tammy Butler, Master CMB

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