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 […]
Category: Truth in Lending
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 […]
CFPB FINALIZES TRID DELAY
On Tuesday the Consumer Financial Protection Bureau (CFPB) issued a final rule extending the effective date of the Truth-in-Lending Act/Real Estate Settlement Procedures Act Integrated Disclosures (TRID) rule to October 3, 2015. The original effective date was set for August 1, 2015. On June 24, 2015, the Bureau proposed a two month extension of the effective date to correct an administrative error that would have delayed the effective date of the rule by at least […]
TRID DELAY PROPOSAL
The Consumer Financial Protection Bureau (CFPB) has issued a 23-page proposed regulation to delay the Truth in Lending/RESPA Integrated Disclosures from August 1, 2015 to October 3, 2015. The delay is appreciated, but some of the explanations are just weird. The delay occurred because a CFPB staffer forgot to send a notice to Congress 60 days prior to the August 1st effective date. By the time the error was discovered a two-week delay, until August […]
TRID DELAY
Today, within hours after the Consumer Financial Protection Bureau (CFPB) announced to 1,700 bankers at the ABA Regulatory Compliance Conference that there would be no delays in TRID (TIL/RESPA Integrated Disclosure Rule) implementation, CFPB Director Richard Cordray issued the following statement: “The CFPB will be issuing a proposed amendment to delay the effective date of the Know Before You Owe rule until October 1, 2015. We made this decision to correct an administrative error that […]