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 […]
Tag: Truth in Lending
CFPB PUBLISHES ADDITIONAL THRESHOLDS FOR REGULATIONS M AND Z
On October 30, 2019 the CFPB published final rules in the Federal Register adjusting exemptions thresholds in Regulations Z and M for the year 2020. Comment 35(c)(2)(ii)-3.vii will be added to the Official Interpretations of § 1026.35 of Regulation Z to increase the threshold amount to $27,200 for the exemption from the special appraisal requirements for higher-priced mortgage loans. Comment 3(b)-3.xi will be added to the Official Interpretations of § 1026.3 of Regulation Z to increase the threshold amount […]
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 […]
QM Changes Considered
On July 25 the Consumer Financial Protection Bureau (CFPB) published a 30-page Advance Notice of Proposed Rulemaking (ANPR) seeking comments relating to the scheduled January 10, 2021, expiration of the temporary qualified mortgage provision applicable to loans eligible for purchase or guarantee by the Government Sponsored Enterprises, Fannie Mae and Freddie Mac. That provision is in the CFPB’s Ability to Repay/Qualified Mortgage (ATR/QM) Rule (section 1026.43 of Regulation Z). The Bureau is considering whether […]