FIVE TRID FAQS ADDED

The Consumer Financial Protection Bureau has added five new questions and answers related to Housing Assistance Loans to the TILA-RESPA Integrated Disclosure FAQs. The new questions, which are effective immediately, cover:

  1. Are housing assistance loans covered by the TRID rule?
  2. What are the criteria for the Regulation Z Partial exemption from the Loan Estimate and Closing Disclosure Requirements?
  3. What are the criteria for the BUILD Act Partial Exemption from the Loan Estimate and Closing Disclosure Requirements?
  4. If a creditor opts for one of the artial exemptions, from which disclosure requirements is the transaction exempt?
  5. Can a creditor provide the Loan Estimate and Closing Disclosure for a loan that qualifies for the BUILD Act Partial Exemption?

This series of questions revolve around the issue of the Regulation Z Partial Exemption. Eligibility requirements for the Partial Exemption include, but are not limited to, a credit contract that:

  • Does not require the payment of interest; and
  • Provides that repayment of the amount of credit extended is forgiven either incrementally or in whole.

Needless to say, typical loan terms do not include these provisions.

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