Archive

UPDATED TRID GUIDANCE

On July 31, the Consumer Financial Protection Bureau updated its TILA-RESPA Integrated Disclosure FAQs by adding five questions related to providing loan estimates to consumers: The questions include: When is a creditor required to provide a loan estimate to a consumer? Can creditors require consumers to provide additional information (other than the six pieces of information constituting an application) in order to receive a loan estimate? Can creditors require consumers to submit verifying documents before they […]

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TRID ASSUMPTIONS FACT SHEET

On May 1 the Consumer Financial Protection Bureau (CFPB) published a fact sheet entitled Are Loan Estimates and Closing Disclosures Required for Assumptions?   The factsheet consists of two parts: (1) a flowchart; and (2) a narrative discussion. The flowchart is a quick reference that highlights the major questions to be answered when determining if a Loan Estimate and Closing Disclosure are required for the assumption transactions described above. The narrative discussion provides general information that […]

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CFPB ISSUES TRID GUIDANCE

On January 25, 2019 the Consumer Financial Protection Bureau released four Frequently Asked Questions (FAQs) Related to TRID. The first three questions deal with corrected disclosures and the three-day waiting period before closing. The final questions involves a form issue. The questions and answers are available below and by clicking here. If there is a change to the disclosed terms after the creditor provides the initial Closing Disclosure, is the creditor required to ensure the […]

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HAPPY NEW YEAR!

2018 was an interesting year for those of us in the compliance field. We completed implementation of HMDA and TRID revisions, and got a jump start on implementing the provisions of the Economic Growth, Regulatory Relief and Consumer Protection Act (EGRRCPA). In last year’s New Years greeting I stated, “In my 42-year career I have seen the pendulum swing from one extreme to another several times. Since the mortgage crisis 10 years ago we have […]

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TWO SMALL ENTITY COMPLIANCE GUIDES UPDATED FOR EGRRCPA

Last week the Bureau of Consumer financial Protection (BCFP) issued revised versions of the small entity compliance guides for the Loan Originator Rule and the Home Ownership and Equity Protection Act (HOEPA) Rule. Both Guides are updated for changes resulting from the Economic Growth, Regulatory Relief, and Consumer Protection Act (EGRRCPA). The Loan Originator Rule, among other requirements,  addresses loan originator compensation, defines the concept of a loan originator and addresses qualification and other requirements related […]

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