CFPB COMMENCES TRID ASSESSMENT

On November 20 the Consumer Financial Protection Bureau (CFPB) announced that it commencing an assessment of its TRID (Truth in Lending Act and Real Estate Settlement Procedures Act Integrated Disclosure) rules.

The CFPB intends to address the TRID Rule’s effectiveness in meeting the purposes and objectives of Title X of the Dodd-Frank Act, the specific goals of the rule, and other relevant factors.  The public is invited to comment on the feasibility and effectiveness of the assessment plan, recommendations to improve the assessment plan, and recommendations for modifying, expanding, or eliminating the TRID Rule, among other questions.

The assessment is being conducted in accordance with Section 1022(d) of the Dodd-Frank Act that requires the Bureau to assess significant rules or orders adopted under Federal consumer financial law. The comment period will open once the notice is published in the Federal Register, which is expected soon, and the deadline for submissions is January 21, 2020.

[Editor’s comments:  It is true that TRID was officially effective on October 3, 2015, but considering that the CFPB did not provide a workable version of the Regulation (TRID 2.0) until October 1, 2018 isn’t the assessment premature? The thought of eliminating TRID is intoxicating until you wake up to the reality that what is likely to replace TRID are the old TIL and RESPA rules (remember the HUD-1). Be careful what you wish for.]

The press release is available here.

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