On Wednesday, Dec. 18, 2019, the Consumer Financial Protection Bureau (CFPB) published two guides on disclosing construction-only and construction-permanent loans with examples based on common questions received by the Bureau. The Combined Guide provides guidance for disclosing the phases together and the Separate Guide provides guidance for disclosing the phases separately. Alternate Headline: CFPB Publishes Inadequate TRID Construction Loan Guidance More Than Four Years After the Effective Date Have you ever heard the old saying , “a day late […]
Tag: TRID
CFPB COMMENCES TRID ASSESSMENT
On November 20 the Consumer Financial Protection Bureau (CFPB) announced that it commencing an assessment of its TRID (Truth in Lending Act and Real Estate Settlement Procedures Act Integrated Disclosure) rules. The CFPB intends to address the TRID Rule’s effectiveness in meeting the purposes and objectives of Title X of the Dodd-Frank Act, the specific goals of the rule, and other relevant factors. The public is invited to comment on the feasibility and effectiveness of […]
TRID AND THE END OF DAYLIGHT SAVING TIME
Daylight Saving Time (DT) ends on November 3, 2019 at 2:00 a.m. What does DT 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 […]
UPDATED TRID GUIDANCE
On July 31, the Consumer Financial Protection Bureau updated its TILA-RESPA Integrated Disclosure FAQs by adding five questions related to providing loan estimates to consumers: The questions include: When is a creditor required to provide a loan estimate to a consumer? Can creditors require consumers to provide additional information (other than the six pieces of information constituting an application) in order to receive a loan estimate? Can creditors require consumers to submit verifying documents before they […]
TRID ASSUMPTIONS FACT SHEET
On May 1 the Consumer Financial Protection Bureau (CFPB) published a fact sheet entitled Are Loan Estimates and Closing Disclosures Required for Assumptions? The factsheet consists of two parts: (1) a flowchart; and (2) a narrative discussion. The flowchart is a quick reference that highlights the major questions to be answered when determining if a Loan Estimate and Closing Disclosure are required for the assumption transactions described above. The narrative discussion provides general information that […]