CFPB, Federal Agencies, State Agencies, and Attorneys General
The CFPB recently updated the TILA/RESPA Integrated Disclosure (TRID) rule FAQs to address construction loans. The guidance falls well short of what the industry is seeking from the CFPB.
Because of the lack of guidance from the CFPB on how to disclose construction loans under the TRID rule, the industry asked Congress to intervene.… Continue Reading
The CFPB recently issued revised TILA/RESPA Integrated Disclosure (TRID) rule guides to reflect the adoption of an amendment to the rule to fix the so-called “black hole” issue. As we reported previously, the amendment will permit the use of an initial or revised Closing Disclosure to reset tolerances without regard to the timing of when before consummation the creditor learns of a change that causes one or more fees to increase. … Continue Reading
As we reported previously, the CFPB recently adopted a long-awaited amendment to the TILA/RESPA Integrated Disclosure (TRID) rule that fixes the so-called black hole issue.
The amendment was published in the May 2, 2018 Federal Register and will become effective on June 1, 2018. The CFPB notes in the supplementary information to the amendment that “[o]nce the final rule becomes effective, the ability to reset tolerances prior to consummation for a given transaction will not be limited by when the application was received.” … Continue Reading
The CFPB, which is now referring to itself as the “Bureau of Consumer Financial Protection,” published the long-awaited final rule to address the so-called “black hole” issue under the TILA/RESPA Integrated Disclosure (TRID) rule. The CFPB also issued an Executive Summary of the final rule. The final rule will become effective 30 days after publication in the Federal Register.… Continue Reading
A federal district court in Kentucky recently handed the CFPB its second defeat in the agency’s lawsuit against Borders & Borders PLC and the law firm’s principals by denying the CFPB’s motion for reconsideration. Significantly, the court based its decision on grounds that are completely different than the basis for its original decision to grant the defendants’ motion for summary judgment.… Continue Reading
On February 14, 2018, the United States House of Representatives passed the TRID Improvement Act of 2017, H.R. 3978, by a vote of 245 to 171. The bill would amend the manner in which title insurance premiums are disclosed under the TILA/RESPA Integrated Disclosure (TRID) rule.
Under title insurance price structures in many states, when a consumer purchases both an owner’s title insurance policy and lender’s title insurance policy at the same time, a discount is offered on the price of the lender’s title insurance policy. … Continue Reading
The Consumer Financial Protection Bureau recently issued an updated version of the TILA-RESPA Integrated Disclosure Guide to the Loan Estimate and Closing Disclosure forms. The revised Guide incorporates the changes to the TRID rule that were issued in July 2017 and published in the August 11, 2017 Federal Register.… Continue Reading
Congress is back in session and this Thursday, September 7, the House Subcommittee on Financial Institutions and Consumer Credit will hold a one-panel hearing entitled “Legislative Proposals for a More Efficient Federal Financial Regulatory Regime.” The hearing will take place at 10:00 a.m. in room 2128 of the Rayburn House Office Building, and will involve the following witnesses:
As we reported previously, on July 7, 2017 the Consumer Financial Protection Bureau (CFPB) posted on its website long awaited amendments to the TILA/RESPA Integrated Disclosure (TRID) rule, and a proposal to address the so-called “black hole” issue (regarding limits on the ability of a credit to reset tolerances with a Closing Disclosure).… Continue Reading
In remarks yesterday at the Mortgage Bankers Association’s annual convention, CFPB Director Richard Cordray stated that the CFPB may need to look more closely at vendors of software and other tools used by lenders to comply with the TILA-RESPA Integrated Disclosure (TRID) rule which became effective on October 3.
Director Cordray stated that he was “disturbed” by reports that such vendors were creating obstacles for lenders attempting to comply with the TRID rule. … Continue Reading
