August 10, 2017

CFPB's TRID 'fix' final rule effective Oct. 10; rule change out for comment

The CFPB's finalized updates to its Truth in Lending Act/Real Estate Settlement Procedures Act integrated mortgage disclosures rule are effective Oct. 10 and carry a mandatory compliance deadline of Oct. 1, 2018.

The rule, also referred to as the TRID "fix," makes adjustments to how disclosures are shared with sellers and third parties. It also addresses tolerance provisions for total payments, incorporates informal guidance into the rule and, among other things, extends the rule's coverage to include all cooperative units rather than just transactions secured by real property.

Another proposed rule change is out for comment until Oct. 10. This CFPB proposal addresses when a creditor can use a closing disclosure instead of a loan estimate to determine if the estimated closing cost was disclosed in good faith. NAFCU will publish a Regulatory Alert summarizing the proposal and seek member feedback.

As the only financial services trade to oppose any CFPB authority over credit unions, NAFCU has long pressed the bureau to improve the TRID rule and related guidance. It continues to push for more clarity.