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 […]
Tag: TRID
CFPB ISSUES TRID GUIDANCE
On January 25, 2019 the Consumer Financial Protection Bureau released four Frequently Asked Questions (FAQs) Related to TRID. The first three questions deal with corrected disclosures and the three-day waiting period before closing. The final questions involves a form issue. The questions and answers are available below and by clicking here. If there is a change to the disclosed terms after the creditor provides the initial Closing Disclosure, is the creditor required to ensure the […]
HAPPY NEW YEAR!
2018 was an interesting year for those of us in the compliance field. We completed implementation of HMDA and TRID revisions, and got a jump start on implementing the provisions of the Economic Growth, Regulatory Relief and Consumer Protection Act (EGRRCPA). In last year’s New Years greeting I stated, “In my 42-year career I have seen the pendulum swing from one extreme to another several times. Since the mortgage crisis 10 years ago we have […]
TWO SMALL ENTITY COMPLIANCE GUIDES UPDATED FOR EGRRCPA
Last week the Bureau of Consumer financial Protection (BCFP) issued revised versions of the small entity compliance guides for the Loan Originator Rule and the Home Ownership and Equity Protection Act (HOEPA) Rule. Both Guides are updated for changes resulting from the Economic Growth, Regulatory Relief, and Consumer Protection Act (EGRRCPA). The Loan Originator Rule, among other requirements, addresses loan originator compensation, defines the concept of a loan originator and addresses qualification and other requirements related […]
CFPB FINAL RULE CLARIFIES REGULATORY BLACK HOLE
On April 28, 2018 the Consumer Financial Protection Bureau (CFPB) finalized an amendment to its Truth in Lending/Real Estate Settlement Procedures Act Integrated Disclosures (TRID) that addresses when a creditor may compare charges paid by or imposed on the consumer to amounts disclosed on a Closing Disclosure, instead of a Loan Estimate, to determine if an estimated closing cost was disclosed in good faith. Under the current rule, circumstances may arise in which a cost […]