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.