CFPB Publishes TRID Guides on Disclosing Construction, Construction-permanent Loans

December 19, 2019

The Consumer Financial Protection Bureau (CFPB) published two guides related to disclosing construction and construction-permanent loans under the TILA-RESPA Integrated Disclosure (TRID) rule.

The first guide is about disclosing construction and construction-permanent loans with a separate Loan Estimate and Closing Disclosure for each phase of the transaction. The second guide is on disclosing one, combined Loan Estimate, and one, combined Closing Disclosure for both phases of a construction-permanent transaction.  

The guides provide illustrative examples for commonly asked about TRID and Regulation Z provisions related to completing these construction and construction-permanent loan disclosures.

The CFPB is currently requesting public comment on an assessment it will conduct on the TRID Integrated Disclosure Rule (TRID).

ALTA’s goal is to help the CFPB create disclosures that accurately and effectively disclose the costs of a product or service. Among ALTA’s areas of opportunity for TRID improvements are to:

  • Correct title insurance fee disclosures
  • Include the ALTA ID on page five of the Closing Disclosure
  • Consider the benefits of adding a page six to the Closing Disclosure to be used as a disbursement document
  • Examine the three-day waiting period

Contact ALTA at 202-296-3671 or