Removing Barriers Blog

CUNA Urges CFPB to Continue with TRID Rule Improvement
Posted October 18, 2016 by CUNA Advocacy

CUNA filed its comment letter with the CFPB on its amendments to the TRID/KBYO Rule under the Truth in Lending Act (Reg Z).  It the letter CUNA thanked the CFPB for agreeing to open the rule to make changes to address implementation challenges that have arisen since the Oct. 3, 2015 effective date.  However, CUNA urged the CFPB to go further and not limit itself to this rulemaking.  In addition to suggesting increased frequency and other channels of providing guidance (such as the use of FAQs), the following improvements were suggested: 

  1. Errors and Cures:  Provide further clarification on what items and when items could be cured.  This will alleviate many of the secondary market’s concerns and lead to greater acceptance of mortgages being transferred.  Further, it will provide certainty as to the liability which will ultimately lead to cheaper and more readily available mortgages for consumers; 

  1. Simultaneous Issue of Title Premiums:  Clarify the circumstance where a title premium can result in a negative number.  This is a concern in certain states; 

  1. The “Black Hole”:  Although the changes did attempt to close the “Black Hole” where the timing requirements for certain situations can be problematic, CUNA urged clarification in the guidance for the application of the changes to rate locks; 

A copy of the letter can be found here.