On February 26, 2020, the Consumer Financial Protection Bureau (“CFPB”) issued frequently asked questions and answers (“FAQs”) concerning compliance with selected topics under the TILA-RESPA Integrated Disclosure Rule (“TRID Rule”). The FAQs cover the following topics:
- Corrected closing disclosures and the three business-day waiting period before consummation
- Model forms
- Construction loans
- Providing Loan Estimates to Consumers; and
- Lender credits
The FAQs are helpful in clarifying common questions related to the TRID Rule. However, as cautioned by the CFPB, the FAQs are not a substitute for reviewing TILA, RESPA, Regulation Z, or its official staff commentary, which are the definitive sources of information regarding the TRID Rule requirement. Nevertheless this caveat, originators are reminded that the FAQs represent CFPB guidance which, according to agencies joint statement, outlines supervisory expectations and articulates the CFPB’s general views regarding appropriate practices on the TRID Rule topics addressed in the FAQs. Therefore, originators will be reasonable to expect that good faith compliance with these FAQs will not carry unfavorable treatment while undergoing supervision and examinations.
If you have any question regarding the TRID Rule or the FAQs, please reach out to Solomon Maman.Download Related Document