TRID

With its recent approval of a trial construction loan disclosure template, the Consumer Financial Protection Bureau (CFPB) took the first step for the bureau’s Trial Disclosure Program toward establishing distinct requirements for construction loans, as opposed to other real estate loan types.

Through ongoing testing efforts, the bureau hopes the program will help to identify and define parameters to guide compliance personnel when interpreting and applying the CFPB’s TILA-RESPA Integrated Disclosures (TRID) rule, also known as “Know Before You Owe” requirements, to construction loan originations.

“The steps we are taking today will help consumers facing financial emergencies obtain access to mortgage credit faster,” CFPB Director Kathy Kraninger said in a release.

Read on for details of what the bureau now considers a changed circumstance.

In 11 reports since the implementation of the TRID rule, only one has contained any guidance from supervisory findings around TRID – that coming in September 2017.

Instead, the latest version of the report – covering the period from April through August 2019 – tackled payday lending, debt collection, mortgage servicing and student loan servicing.

But the most revealing moments might have come in two of the CFPB’s most recent enforcement cases.

Read on for details from Kraninger’s appearance, including her response to notions that the CFPB was weak in its handling of a recent bank enforcement action.

Various trade advocates pointed to the additional cost burdens associated with TRID regulations and questioned whether those regulations have had the desired effect.

Advocates for both community banks and credit unions, in particular, cited numerous concerns pertaining to TRID’s impact on compliance costs and its impact on their effect on smaller institutions’ ability to compete with their larger industry counterparts.

Learn more about the industry’s concerns.

Sitting in the crosshairs of the Consumer Financial Protection Bureau’s (CFPB) five-year look-back agenda is the TILA-RESPA Integrated Disclosure (TRID) rule.

That fact theoretically could lead to changes to TRID provisions.

Get more information about what the bureau is hoping to learn about the rule’s impact.

Consumer Financial Protection Bureau (CFPB) Director Kathy Kraninger responded to calls from industry stakeholders and senators for the bureau to update TILA-RESPA Integrated Disclosure (TRID) requirements to improve the accuracy of information collected.

Her response indicated that any potential TRID changes may not happen until at least 2020, when the bureau is statutorily required to assess the rule’s effectiveness.

Find out more details about her response and the concerns raised by stakeholders.

The period of voluntary compliance is over with respect to the Consumer Financial Protection Bureau’s (CFPB) TILA-RESPA Integrated Disclosure (TRID) amendments. However, TRID compliance remains tantamount to a moving target some in the industry just can’t seem to hit.

As the updated TRID provisions have taken effect, many continue to struggle with the disclosure requirements implemented three years ago as regulators have gotten more technical in their examinations.

Why are examiners’ increasingly focusing on technical aspects of TRID and what can lenders do to avoid violations?

At the 2018 National Settlement Services Summit (NS3) in Detroit, panelists addressed how title agents, the keepers of critical data “gold,” can best leverage it to acquire market share and business. The title agent is at the center of the closing transaction and captures critical data elements that lenders need to meet for compliance.

DocMagic eServices Director Tim Anderson and Pepper Hamilton, LLP, Special Counsel John Levonick told the audience that despite two years of TRID and now with the new FHFA Uniform Closing Dataset (UCD) requirement, most processes are still very manual so they keep asking the regulatory agencies and GSEs to water down and delay the requirements. 

Read on to learn more. 

Advocating for single-family residential construction loans to be exempt from TILA-RESPA Integrated Disclosure (TRID) requirements, more than 100 bankers made their case in a letter to Consumer Financial Protection Bureau (CFPB) acting director Mick Mulvaney.

The bankers argued that TRID requirements have created confusion for consumers and caused many banks to exit the market because of the associated costs and strict compliance standards for the underwriting and construction process.

Find out what the bankers had to say in their letter.