Archive

CFPB SPRING 2020 AGENDA

On June 30, 2020, the Consumer Financial Protection Bureau (CFPB) published its Spring 2020 Agenda. The agenda lists the regulatory matters that the CFPB expects to focus on between May 1, 2020 and April 30, 2021. Those matters include: A final rule amending the CFPB’s Remittance Rule to provide tailored exceptions that permit certain insured institutions to disclose estimates instead of exact amounts to consumers in certain circumstances. The final rule also increases (from 100 remittance […]

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RECENT TRID GUIDANCE – FACTSHEET AND FAQS

On June 9 the Consumer Financial Protection Bureau (CFPB) published a nine-page booklet entitled Factsheet:  TRID Title Insurance Disclosures. The factsheet clarifies the disclosures for both Lender and Owner’s Title Insurance, including the disclosure of a simultaneous issuance. Several helpful examples are included. On June 9 the CFPB also published three new Frequently Asked Questions (FAQs). The new FAQs explain: Seller-Paid Loan Costs and Other Costs on Separate Closing Disclosures to the Seller and the […]

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CORONA RELIEF – TRID AND RESCISSION WAITING PERIODS

On April 28 the Consumer Financial Protection Bureau (CFPB) released an Interpretative Rule that concludes that a consumer has a “bona fide personal financial emergency” if the consumer determines that his or her need to obtain funds due to the COVID-19 pandemic Necessitates consummating the credit transaction before the end of the TRID Rule waiting periods or Must be met before the end of the Regulation Z Rescission Rules waiting period. Under such circumstances the […]

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TRID AND DAYLIGHT SAVING TIME

Daylight Saving Time (DT) begins on Sunday March 8, 2020 at 2:00 a.m. It ends on November 1, 2020 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 […]

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