integrated disclosures

In his remarks at the Mortgage Bankers Association’s annual meeting in Boston on October 25, Director Cordray signaled that mortgage servicing will continue to be a focus of CFPB supervisory and enforcement activity, with the CFPB taking a rigorous approach to compliance.  

While noting that the CFPB has seen “some progress” in compliance with CFPB

The FDIC has revised its interagency examination procedures to reflect the requirements of the TILA/RESPA integrated disclosures (TRID) rule.  The CFPB has issued a proposal to postpone the TRID rule’s effective date from August 1 to October 3, 2015.

The revised procedures also reflect the following amendments to other provisions of TILA Regulation Z and

While not agreeing to the grace period from enforcement sought by lawmakers and industry, Director Cordray stated in a letter sent yesterday to members of Congress that the CFPB “will be sensitive to the progress made by those entities that have squarely focused on making good-faith efforts to come into compliance with the [TILA/RESPA

The CFPB has revised the chapters of its Supervision and Examination Manual specific to TILA and RESPA, incorporating the TILA/RESPA integrated disclosures (TRID) requirements that are set to take effect on August 1, 2015.  These chapters replace versions of the TILA and RESPA procedures released on November 27, 2013.

As is the case for most

A group of 17 trade associations and organizations have written to the CFPB seeking a grace period for enforcement of  the TILA-RESPA Integrated Disclosure (TRID) rule which becomes effective on August 1, 2015.

In their letter, the groups seek written guidance from the CFPB on various situations not addressed by the TRID rule and

On Tuesday, January 20, the CFPB promulgated its first final rule of 2015, a series of minor amendments to the TILA/RESPA integrated disclosures (TRID) rule.  The substantive changes to the TRID rule are (1) an extension of the time period to issue a revised Loan Estimate when an interest rate moves from floating to locked,

On October 1, 2014, the CFPB staff and Federal Reserve Board co-hosted a webinar that addressed questions about the Final TILA-RESPA Integrated Disclosure Rule that will be effective for applications received by creditors or mortgage brokers on or after August 1, 2015.  The webinar focused on the Loan Estimate and addressed specific questions regarding the content of the Loan Estimate form that relate to corresponding provisions of the Closing Disclosure.   Many of the issues covered were in response to questions received by the CFPB from mortgage industry stakeholders and technology vendors who need additional information in order to facilitate the development of compliance and quality control procedures and software.

The webinar is the third in a planned series to address the new rule.  In the initial webinar, the CFPB staff provided a basic overview of the final rule and new disclosures.  In the second webinar, the CFPB staff focused on core operation issues such as the receipt of an application, assumptions, fee tolerances, record retention, and timing for the initial and revised Loan Estimates.

According to the CFPB staff, this webinar and the ones that will follow will be in the format of a spoken Q&A.  Although the CFPB staff does not plan to issue written Q&A, the staff believes this approach will help facilitate clear guidance on the new rules in an accessible way.  As we have stated before, industry members would prefer formal written guidance.  Among other concerns, the CFPB approach presents challenges to the ability of hearing impaired individuals to benefit from the guidance.

During the webinar the CFPB staff provided a high-level overview of the rule and answered more than thirty technical questions.  Below is a summary of select questions of interest addressed by the CFPB staff.  The topics covered include: (1) brokered transactions, (2) origination charges, (3) calculating cash to close, and (4) the adjustable payment and adjustable interest rate tables. 
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