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In late July the CFPB published almost 300 pages of proposed revisions to TRID. Normally we don’t schedule programs based on proposed regulations; we wait for the final regulations. The final regulations for this proposal are expected in the first quarter of 2017.
This case is a little different. There are so many unanswered TRID questions and bankers are desperate for answers. Instead of making decisions based on pure speculation, these proposed regulations provide a strong indication of where the CFPB is headed. It is the most reliable guidance currently available.
The proposal memorializes certain past informal guidance, whether issued through webinar, compliance guide, or otherwise, and makes additional clarifications and technical amendments. Clarification is provided for dozens of areas. Major proposed provisions include:
- Creating tolerances for the total of payments similar to the existing provisions regarding the finance charge;
- Expanding a partial exemption for certain non-interest bearing subordinate lien transactions that provide down payment and other homeowner assistance (housing assistance loans) that is rarely used;
- Clarifying coverage for cooperative units;
- Clarifying rules for sharing of disclosures with sellers and various other parties, including real estate agents, involved in the origination process in light of privacy concerns.
The industry – lenders, loan origination software providers, auditors, and others – are still struggling to understand the Truth-in-Lending/Real Estate Settlement Procedures Integrated Disclosure (TRID) rules. The recent proposed regulations provide much needed clarity. This two-hour program reviews and explains the massive proposal.
Upon completion of the program, participants understand the proposed changes to:
- Affiliate charges;
- Calculating cash to close table;
- Construction loans;
- Decimal places and rounding;
- Escrow account disclosures;
- Escrow cancellation notices;
- Expiration dates for the closing costs disclosed on the Loan Estimate;
- Gift funds;
- The “In 5 Years” calculation;
- Lender and seller credits;
- Lenders’ and settlement agents’ respective responsibilities;
- The list of service providers;
- Model forms;
- Non-obligor consumers;
- Partial payment policy disclosures;
- Payment ranges on the projected payments table;
- The payoffs and payments table;
- Payoffs with a purchase loan;
- Post-consummation fees;
- Principal reduction (principal curtailment);
- Disclosure and good faith determination of property taxes and property value;
- Rate locks;
- Recording fees;
- Simultaneous second lien loans;
- The summaries of transactions table;
- The total interest percentage calculation; and
The program is designed for loan officers, compliance officers, loan processors and clerks, auditors, and anyone else with responsibilities related to TRID loans.