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The CFPB has released answers to frequently asked questions about its TILA/RESPA integrated disclosure (TRID) rule. One of the questions is related to a provision of S. 2155 on which NAFCU previously requested clarity from the bureau; the bureau has since indicated that it is not required to issue a rulemaking to implement this section.

Question 3 of the FAQs clarifies that the bureau believes Section 109 of S. 2155 was intended to only amend that part of TILA relating to high cost mortgages. NAFCU's S. 2155 summary guide provides some additional detail; NAFCU's Compliance Blog will provide more details on the FAQs soon.

In addition to the three questions under the corrected closing disclosures and three business-day waiting period before consummation, there is one question on whether a creditor's use of a model form provides a safe harbor if the model form doesn't reflect a finalized TRID change.

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.

Under its fall rulemaking agenda, the bureau indicated it would issue an assessment of the TRID rule this year. 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.