CFPB Makes Minor Change to Property Tax Rules
The Consumer Financial Protection Bureau (CFPB) made a correction to the preamble to the Integrated Mortgage Disclosures Under the Real Estate Settlement Protections Act and the Truth in Lending Act (TRID).
The correction, effective February 10, 2016, corrects a typo. Specifically, on page 79,829 of Volume 78 of the Federal Register, in the first column, in the sentence containing “property insurance premiums, property taxes, homeowner’s association dues, condominium fees, and cooperative fees,” the phrase “are subject to tolerances” now reads “are not subject to tolerances.”
Consequently, even though the actual regulation and commentary have not been changed, it is now pretty clear that taxes and homeowner association/condo dues and fees are not subject to any TRID tolerances.
CLA’s financial institution regulatory compliance team assists banks and credit unions nationwide in establishing regulatory compliance programs, conducting compliance testing, and training staff on regulations. Justin Robinson is a member of CLA’s regulatory compliance team and can be reached at justin.robinson@CLAconnect.com.
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