The CFPB’s Truth in Lending Act/Real Estate Settlement Procedures Act integrated disclosure rule (TRID), also known as the “Know Before You Owe” rule, addresses tolerance provisions for the total of payments, incorporates informal guidance into the rule, and extends the rule’s coverage to include all cooperative units rather than just transactions secured by real property, among other things.
The CFPB also issued a proposal addressing when a creditor can use a closing disclosure instead of a loan estimate when determining if the estimated closing cost was disclosed in good faith.
“As the only financial services trade to oppose any CFPB authority over credit unions, NAFCU has long pressed the bureau to improve the TRID rule and related guidance,” National Association of Federally Insured Credit Unions Vice President of Regulatory Compliance Brandy Bruyere said. “NAFCU will continue to push for more clarity and transparency wherever possible in the CFPB’s approach to TRID compliance.”
The proposal will be out for a 60-day comment period once published in the Federal Register. It has a mandatory compliance date of Oct. 1, 2018.
David Stevens, president and CEO of the Mortgage Bankers Association (MBA), concurred that more clarity is needed.
“MBA appreciates the CFPB’s efforts in amending the Know Before You Owe rule to address several significant questions that have been raised for some time by our industry,” Stevens said. “This is an extensive rule and we intend to review it closely with our members. We note that CFPB has proposed a new rule to deal with issues concerning needed revisions to the Closing Disclosure during the mortgage process that we will carefully review and comment on as well. MBA looks forward to continuing to work with the CFPB on rules and guidance to provide greater clarity to better protect consumers.”