June 03, 2019

CFPB releases FAQ on TRID rule

CFPB HeadquartersThe CFPB released its  first set of frequently asked questions (FAQ) on the TILA-RESPA Integrated Disclosure (TRID) rule as it applies to construction loans.

Through the FAQ, the bureau covers questions related to:

  • corrected closing disclosures and the three business-day waiting period before consummation;
  • model forms; and
  • construction loans.

The bureau notes that these are meant to supplement the statutes, Regulation Z and its official interpretations, which are the definitive sources of information regarding the rule's requirements.

The bureau released an FAQ on compliance with the TRID rule earlier this year, and NAFCU's Director of Regulatory Affairs Ann Kossachev wrote the CFPB to suggest additional areas where FAQs would provide significant clarity and assistance to credit unions. Those included: cure provisions and error corrections, negative owner’s title insurance premium, calculating cash to close, second lien loans, pre-approvals/pre-qualifications and payoff in a purchase money loan.

NAFCU has various resources available on TRID, including two popular blogs: One that explains the bureau's fix to the TRID "black hole," and another detailing "TRID 2.0" compliance deadline related to statutory damages and errors in loan estimate or closing disclosure.