Daylight Saving Time (DT) begins on March 13, 2016. What does that have to do with TRID? The TRID rules under Regulation Z require creditors to disclose the time zone applicable to its location when disclosing the date and time the interest rate lock and estimate of closing costs will expire on the loan estimate. As a result, financial institutions located in areas that observe DT need to remember to change the time designation used […]
Category: Integrated Disclosures
TRID CORRECTION PUBLISHED BY CFPB
Can you believe that title? The CFPB has actually published something for us in writing in the Federal Register that will clear up an item that has been a source of confusion since prior to the implementation of TRID. The publication in the Federal Register dated yesterday, February 10th, results in a correction to the Supplementary Information of the final rule to correct a typographical error. Specifically, section 1026.19(e)(3)(iii) – Variations Permitted for Certain Charges […]
CFPB V LOS VENDORS – SHOT ACROSS THE BOW
In remarks at the recent Mortgage Bankers Association Convention Consumer Financial Protection Bureau Director Richard Cordray conceded that the implementation process for CFPB’s new “Know Before You Owe” mortgage disclosure rule (aka as TRID) has not been as smooth as the agency would have hoped. But Cordray faulted vendors, not regulators. “Quite frankly, I have been disturbed by reports I have been hearing about the vendors on whom so many of you rely,” he said. […]
TRID DISCLOSURE FOR PREFERRED-RATE LOANS
Typical preferred-rate loans might include a fixed-rate mortgage loan that carries a preferred rate as long as the borrower remains an employee of the financial institution or as long as a deposit account remains open. This loan type raises several issues under TRID rules including, which product description should be used. The product description, explained in §1026.37, must classify the rate as “Adjustable Rate,” “Step Rate,” or “Fixed Rate.” For an “Adjustable Rate” the rates […]
CHANCE TO BREATHE
I lot of people seemed to think that once the August 1 TRID deadline arrived life would be much easier. Well today is August 1, and the future doesn’t look any easier. TRID has been delayed until October 3, 2015; New interagency flood insurance regulations are effective, in large part, on October 1, 2015, with the new escrow rules unfolding on January 1, 2016; The new Military Lending Act regulations, which look like the real […]