Right on the heels of the release of the 2017 TRID-RESPA Amendments final rule, the CFPB released a proposal today that also impacts TRID. The proposed amendment released in July 2016 contained comments related to utilizing a Closing Disclosure to determine if a closing cost was disclosed in good faith. The CFPB determined, based on comments received from the proposal, that many thought the amendment “would broaden creditors’ ability to compare charges paid by or […]
Category: Truth in Lending
LONG AWAITED REVISIONS TO TRID FINALIZED
The time has finally come, the proposed revisions to the 2015 Integrated Disclosures Rule (TRID) were released in final form today, July 7, 2017. The proposed amendments to TRID were released in July 2016 and gave all compliance professionals a glimpse into the direction the CFPB was headed with the amendments; the proposal provided much needed clarification on many confusing aspects of TRID, including construction loans. The 560 pages of the 2017 TILA-RESPA Amendments are […]
ATR/QM ASSESSMENT
The Dodd-Frank Act (DFA) requires the CFPB to review certain rules within five years after they take effect. The required reviews are called assessments. The CFPB is conducting an assessment of the ATR/QM rule, and will issue a report of the assessment by January 2019. As required by law, the assessment will address the rule’s effectiveness in meeting the purposes and objectives of Title X of the Dodd-Frank Act and the specific goals of the […]
TRID AND DAYLIGHT SAVINGS TIME
Daylight Saving Time (DT) begins on March 12, 2017. 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 […]
REVISED SMALL ENTITY COMPLIANCE GUIDE FOR MORTGAGE SERVICING RULES
On November 30, 2016 the Consumer Financial Protection Bureau published an updated version of the Small Entity Compliance Guide entitled Real Estate Settlement Procedures Act (Regulation X) and Truth In Lending Act (Regulation Z) Mortgage Servicing Rules. The Guide is updated to reflect the August 2016 Final Rule that makes significant changes to the servicing rules contained in both regulations. The August 2016 Final Rule changes impact all financial institutions. The impact on small servicers […]