October 11, 2017

CFPB's TRID guide now covers construction loans, tolerances

The CFPB updated its TILA/RESPA integrated disclosure rule's (TRID) small-entity compliance guide with new guidance on construction loans and tolerance provisions for the total of payments, which credit unions may find useful as they work to comply with the revised rulemaking.

The small-entity compliance guide incorporates amendments and clarifications included in the CFPB's final rule, also referred to as the TRID "fix," issued in July. Additional updates to the guide include:
  • disclosing cures for tolerance violations;
  • requirements and guidance on current requirements for tolerances in the good faith analysis;
  • requirements and guidance for providing revised loan estimates;
  • requirements for permitting a consumer to shop and providing the written list of service providers;
  • coverage for cooperative units, trusts, and the partial exemption for certain housing assistance loans;
  • guidance on lender and seller credits, including impacts to the good faith analysis;
  • guidance on disclosing transactions with a simultaneous subordinate-lien loan;
  • requirements for providing corrected closing disclosures for changes to per diem interest;
  • guidance on sharing disclosures with third parties; and
  • the safe harbor provided by correct use of sample forms.
NAFCU also has myriad resources available to credit unions on CFPB's TRID rule, including blog posts, a scope-and-applicability chart and a final rule summary. The most recent edition of NAFCU's Compliance Monitor (member-only) also provides an overview of the rule.