Archive

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 […]

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TRID AND THE END OF DAYLIGHT SAVING TIME

Daylight Saving Time (DT) ends on November 3, 2019 at 2:00 a.m. What does DT have to do with TRID? The TRID rules under Regulation Z require creditors to disclose the time zone applicable to its location when disclosing the date and time the interest rate lock and estimate of closing costs will expire on the loan estimate. As a result, financial institutions located in areas that observe DT need to remember to change the […]

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SPECULATION ABOUT THE CFPB’S PENDING TRID PROPOSAL

As a result of a lot of pressure from many players in the mortgage lending game the CFPB has reluctantly agreed to publish proposed rules to clarify the massive pile of confusion that is called TRID. Recently CFPB Director Cordray sent a letter to the leadership and members of several industry trade groups reporting that the agency has begun drafting a Notice of Proposed Rulemaking on the TRID rules. Cordray stated the goal for publication […]

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CFPB V LOS VENDORS – SHOT ACROSS THE BOW

In remarks at the recent Mortgage Bankers Association Convention Consumer Financial Protection Bureau Director Richard Cordray conceded that the implementation process for CFPB’s new “Know Before You Owe” mortgage disclosure rule (aka as TRID) has not been as smooth as the agency would have hoped. But Cordray faulted vendors, not regulators. “Quite frankly, I have been disturbed by reports I have been hearing about the vendors on whom so many of you rely,” he said. […]

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TRID DISCLOSURE FOR PREFERRED-RATE LOANS

Typical preferred-rate loans might include a fixed-rate mortgage loan that carries a preferred rate as long as the borrower remains an employee of the financial institution or as long as a deposit account remains open.  This loan type raises several issues under TRID rules including, which product description should be used. The product description, explained in  §1026.37, must classify the rate as “Adjustable Rate,” “Step Rate,” or “Fixed Rate.” For an “Adjustable Rate” the rates […]

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