TRID Amendments and Proposal Published in Federal Register
August 15, 2017
The Consumer Financial Protection Bureau’s amendments and proposal to the TILA-RESPA Integrated Disclosure rule were published to the Federal Register on Aug. 11.
The official effective date of the amendments is Oct. 10, 2017. From that date until Oct. 1, 2018, each lending institution will get to choose which of the amendments to comply with. Title and settlement companies will need to be flexible during this year to account for settlements that will use different rules on the same, exact day. A good first step to prepare for the inevitable confusion is to talk to your largest lender customers to understand which items they are prioritizing during their implementation.
Additionally, the comment deadline for the proposal to fix the so-called "TRID black hole" is also Oct. 10. The CFPB has proposed to allow lenders to update tolerances during a valid changed circumstance using a Closing Disclosure at any time after the initial disclosure is issued. This would replace the complex timing requirements in the current rule.
More on the CFPB’s TRID amendments:
- CFPB Keeps Onus on Lenders for Determining to Share Closing Disclosure
- CFPB Fails to Fix Inaccurate Disclosure of Title Fees in TRID Update
Contact ALTA at 202-296-3671 or communications@alta.org.