The CFPB recently announced that it is seeking input on a trial disclosure sandbox application from the Independent Community Bankers Association (ICBA) for alternative disclosures under the Truth in Lending Act (TILA)/Real Estate Settlement Procedures Act (RESPA) Integrated Disclosure (TRID) rule for construction and construction-to-permanent loans. The application is a template application, which means that if even approved by the CFPB it will not actually be operative. … Continue Reading
CFPB Publishes TRID FAQ’s and a Factsheet on Treatment of Title Insurance Premiums
On June 9, 2020, the CFPB published four new TRID FAQ’s and a TRID Factsheet (“Factsheet”). While the Factsheet is focused solely on the handling of title insurance disclosures under the rule, the FAQ’s cover various topics, including the separation of data when using separate Closing Disclosures for the consumer and the seller, the Total of Payments calculation, and the optional signature lines on the Loan Estimate and Closing Disclosure.… Continue Reading
CFPB Issues Guidance on Applicability of TRID Rule to Assumptions
The CFPB recently issued a factsheet addressing whether a Loan Estimate and Closing Disclosure are required in connection with the assumption of a residential mortgage loan.
As previously reported, the Economic Growth, Regulatory Relief, and Consumer Protection Act (Growth Act) includes a sense of Congress provision that the CFPB should endeavor to provide clearer, authoritative guidance on the applicability of the TRID rule to mortgage loan assumptions.… Continue Reading