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 […]
Tag: TRID
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 […]
TRID PROPOSAL
“The Consumer Financial Protection Bureau has begun drafting a Notice of Proposed Rulemaking (NPRM) to make adjustments to the Know Before You Owe rule,” CFPB director Richard Cordray told industry trade groups in an April 28 letter. Cordray said he hopes the NPRM will be issued in late July. Well his “hopes” became reality late last week. On July 28 the CFPB Published a 293-page proposal. The proposal has a quick 82-day comment period, which […]
STILL TRID-ING WATER IN SAN DIEGO
Greetings from the Manchester Grand Hyatt in sunny San Diego, CA! The locals say we are in the middle of the “June Gloom” with some hazy weather but there is plenty of energy at the ABA regulatory compliance gathering. Hundreds in the banking compliance community have come together to share knowledge and make connections with other like-minded professionals. As always, the ABA puts on a premier event with offerings in subjects across the entire spectrum […]
LIABILITY AFTER FORECLOSURE – THE SEQUEL
Last fall, we published a blog article that reviewed the intricacies of the “Liability after Foreclosure” disclosure. Here we provide a quick update and add some valuable new information. As a refresher, the following disclosure appears in the Loan Estimate but only when the transaction is defined as a refinance: Liability after Foreclosure Taking this loan could end any state law protection you may currently have against liability for unpaid debt if your lender forecloses […]