Newsroom

October 04, 2017

TRID fix focus of October's Monitor

In this month's Compliance Monitor, now available for download, NAFCU Vice President of Regulatory Compliance Brandy Bruyere provides an overview of the CFPB's finalized amendments to the Truth in Lending/Real Estate Settlement Procedures Act integrated disclosures rule (TRID).

In the article, Bruyere said that while the amendments are highly technical, they are meant to clarify ambiguities in the original rule.

"Overall, the finalized amendments to TRID may help in applying some of the more ambiguous sections of the rule and the CFPB's proposal to resolve the black hole issue is promising," Bruyere wrote. "Some of the amendments may already be how credit unions are complying with TRID as the rule incorporates past informal guidance the industry has already relied upon. Still, the amendments are quite technical and will take time to review and fully implement."

Key changes to TRID as a result of the finalized amendments include:

  • expanding the scope of TRID;
  • clarifying how to calculate tolerances and provide consumers with a written list of service providers;
  • addressing the disclosure of principal reductions; and
  • adding additional commentary and guidance specific to both construction loans and simultaneous "piggyback" loans.

Bruyere noted that the CFPB has not yet updated its Small Entity Compliance Guide, but she expects it to do so soon. She also highlighted NAFCU's consolidated regulatory text of the amendments and other resources available to assist credit unions.

Read the full article about the TRID amendments, including the effective dates and a more detailed explanation of the changes here.

Also in this month's Monitor, NAFCU regulatory compliance staff answered questions about account disclosures, pulling credit reports, and credit limit increases, and there are recent credit union news snippets and upcoming education opportunities.