tila-respa integrated mortgage disclosures rule

In today’s Federal Register the CFPB published a correction to the TILA/RESPA Integrated Disclosure (TRID) rule supplementary information as published on December 31, 2013 with regard to property taxes and certain similar charges.  The move apparently is intended to address an apparent oversight in the TRID rule regarding the treatment for tolerance purposes of property taxes and similar charges paid in advance, but not into an escrow or impound account. … Continue Reading

Reacting to reports of investors refusing to purchase loans based on various, often technical, violations of the TILA/RESPA Integrated Disclosure (TRID) rule, the Mortgage Bankers Association (MBA) sent a letter to the CFPB on December 21, 2015 seeking guidance to allay investor concerns.  (The version of the letter released by the MBA does not include the attachment referenced in the letter.)… Continue Reading

The CFPB has issued a final rule containing “technical corrections” to the final TILA-RESPA Integrated Disclosure (TRID) rule that became effective on October 3, 2015.  The corrections are effective December 24, 2015, the date of their publication in the Federal Register.

According to the supplementary information accompanying the corrections, the publication of the TRID rule in the Federal Register “resulted in several unintended deletions of existing regulatory text from Regulation Z and the Official [Regulation Z Commentary] and, in one case, the omission of regulatory language in the [final TRID rule] from the [Code of Federal Regulations].” … Continue Reading

A bipartisan group of 255 members of Congress have sent a letter to the CFPB seeking a grace period for enforcement of  the TILA-RESPA Integrated Disclosure (TRID) rule which becomes effective on August 1, 2015.  They ask for the grace period to apply to “those seeking to comply in good faith from August 1st through the end of 2015.”… Continue Reading

Statements made by CFPB Director Cordray to the National Association of Realtors on May 12, 2015 suggest that the Director may not fully appreciate the implications of the TILA/RESPA Integrated Disclosure (TRID) rule that is scheduled to become effective August 1, 2015.

The TRID rule requires that the combined consummation disclosure, which is called the “Closing Disclosure,” be received by the borrower at least three business days before consummation. … Continue Reading

On May 14, 2015, the House Financial Services Committee’s Subcommittee on Housing and Insurance will hold a hearing on “TILA-RESPA Integrated Disclosure: Examining the Costs and Benefits of Changes to the Real Estate Settlement Process.”

While the witnesses have not yet been announced, it is likely that the hearing will feature a renewed call from subcommittee members for the CFPB to provide a grace period from enforcement of the TILA-RESPA integrated disclosure (TRID) rule which is set to take effect on August 1, 2015. … Continue Reading

Republican Congressman Steve Pearce and Democratic Congressman Brad Sherman have introduced a bill in the House of Representatives (H.R. 2213) that would provide lenders with a temporary safe harbor from enforcement of the TILA-RESPA integrated disclosure (TRID) rule which is set to take effect on August 1, 2015.

The bill provides that the TRID rule cannot be enforced against any person before
January 1, 2016 and no suit can be filed against any person for a violation of the TRID rule occurring before that date if such person has made a good faith effort to comply with the TRID rule.… Continue Reading

On November 18, the CFPB and the Federal Reserve will co-host the fourth in a series of webinars on the TILA-RESPA integrated mortgage loan disclosures rule.  The webinar will focus on how to complete the new closing disclosure form.  A link to register is available here.

See our prior blog posts for details about the information provided to participants at the three webinars conducted earlier this year on June 17, August 26, and October 1.… Continue Reading

The CFPB has released Version 3.0 of its “2014 CFPB Dodd-Frank Mortgage Rules Readiness Guide.”  The Guide, originally issued in July 2013, now contains changes to the final rules issued through August 1, 2014.  The updated Guide includes the TILA-RESPA Integrated Mortgage Disclosures Rule that takes effect in August 2015.

According to the CFPB, the Guide provides guidelines to “help financial institutions come into and maintain compliance with the new mortgage rules.” … Continue Reading