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 and a dollar short.”
The TRID construction loan rules were effective on October 3, 2015. We certainly could have used this guidance then. But I guess the old saying “better late than never” applies.
Both of the new guides have at least one glaring hole. They do not mention the cash to close section of the Loan Estimate or the Closing Disclosure and there are no sample forms for those sections. Could this be an oversight. The CFPB states that the guides are based on “common questions received by the Bureau.” Maybe no one has ever asked the CFPB for clarification for the cash to close section. My guess – the CFPB could not provide a clear, concise explanation for how to properly disclose the cash to close section of the forms, so they just skipped it.
Bah humbug! My office has accused me of sounding like Scrooge this morning.