The CFPB staff presented an informational webinar on Tuesday, April 12, 2016, to address several issues with the TILA/RESPA Integrated Disclosure (TRID) rule.  The webinar, titled Know Before You Owe Mortgage Disclosure Rule: Post-Effective Date Questions & Guidance, focused on responding to specific industry raised questions.  Specific topics of discussion included:

  • Determining what fees must be disclosed;
  • APR changes that require a new 3-day waiting period;
  • Lender and seller credits as they relate to the APR and finance charge;
  • The calculation of the Total Interest Percentage (TIP);
  • Disclosure of the owner’s title insurance policy premium when disclosures produce a negative premium amount;
  • Flood insurance premium disclosures;
  • Disclosure of escrow account balances credited from an existing loan;
  • Separate borrower and seller Closing Disclosures;
  • Disclosure of whether a loan is assumable;
  • How to address upfront fees collected from the consumer for items that cost less than the collected amount; and
  • Disclosure of a principal curtailment.

As we have previously written for the last TRID rule webinar, the fact that the entire presentation appeared to be scripted word-for-word was interesting considering the fact that the CFPB has refused industry requests to issue informal guidance in writing.