CFPB Issues Updated TRID Compliance Guides
October 2016, the Consumer Financial Protection Bureau (CFPB) published two updated guides pertaining to the Truth in Lending Integrated Disclosure (TRID) rule, a Guide to Forms booklet and a Small Entity Compliance Guide. The Small Entity Compliance Guide provides additional clarity and/or reflects changes made to the rule since the original guide was issued in April 2014. The updated topics are summarized below:
October 2016 Updates
- Record retention requirements for the Closing Disclosure
- Completing the Loan Estimate and Closing Disclosure
- Formatting the Loan Estimate and Closing Disclosure
- Delivery requirements for the Loan Estimate and the special information booklet
- Requirements upon receiving an application
- Disclosing and determining good faith for services the borrower may shop
- Disclosing seller-paid costs and providing seller disclosures
- Providing revised Loan Estimates and corrected Closing
- Guidance on construction loans
- Providing special information booklet
- The absence of a HUD-1 comparison chart in the Closing Disclosure
- Additional guidance on providing revised Loan Estimates any time before the Closing Disclosure
2015 Updates
- Extends the timing requirement for revised disclosure when consumers lock a rate or extend a rate lock after the Loan Estimate is provided
- Permits certain language related to construction loans for transactions involving new construction on the Loan Estimate
- Additional clarification on questions relating to the Loan Estimate and the 7 day waiting period
- Additional clarification on questions relating to Timing for Revisions to Loan Estimate
Updates to Forms
The second guidebook issued in October 2016 provides an illustrative guide to forms completion. A number of revisions are included in this publication, including the following changes made in October:
Loan Estimate:
Projected Payments Table, Loan Costs, Other Costs, Adjustable Payment Table, Adjustable Interest Rate Table, Contact Information, and Other Considerations sections.
Closing Disclosure:
General Information, Projected Payments Table, Loan Costs, Other Costs, Loan Disclosures, Escrow Disclosures, and Other Disclosures sections.
The Small Entity Compliance Guide and the Guide to Forms
TILA-RESPA Integrated Disclosure
Anna DeSimone founded Bankers Advisory in 1986 and is a nationally recognized authority in residential mortgage lending. She has received numerous industry awards and has authored more than 40 best practices guides and hundreds of articles.
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