The Consumer Financial Protection Bureau (CFPB) issued a number of CUNA-requested clarifications Friday to its Truth in Lending Act-Real Estate Settlement Procedures Act integrated disclosure (TRID) rule.  The original rule went into effect on October 3 last year and was a major overhaul of the closing process.  We have been urging the CFPB to make many changes that became readily apparent once implementation of the rule commenced.

Although the CFPB did not address all of our requested changes, it is an excellent development as the CFPB initially was hesitant to do any additional rulemaking on this newly promulgated rule. 

Some of the areas addressed are as follows: 

• Creating tolerances for the total of payments that brings it in line with how these were treated pre-TRID;
• Extending the rule’s coverage to include all cooperative units as there were differences under state law as to how coops were treated under the TRID rule;
• Providing guidance on sharing disclosures with various parties involved in the mortgage origination process, as there have been issues particularly with respect to sharing closing documents with realtors; and
• Construction loans, there is needed clarity with the treatment of these loans under the rule.

Comments are due Oct. 18 and we will be reaching out to all members for input as well as providing a comprehensive summary of the proposal.