CFPB Updates Mortgage Origination Examination Procedures to Include Requirements of TILA-RESPA Integrated Disclosure Rule

CFPB Examination TRID Mortgage Origination

On May 4, the CFPB updated its Supervision and Examination Manual’s Mortgage Origination examination procedures to include guidance on how its compliance examiners will examine loan disclosures and terms of closed-end residential mortgage loans that are subject to the TILA-RESPA Integrated Disclosure (TRID) rule. The TRID examination procedures updates are reflected in module 4 of the Manual’s 8 modules, and instruct compliance examiners to review a sample of complete loan files to determine a company’s compliance. Further, if consumer complaints exist concerning the mortgage origination and closing disclosure requirements, then compliance examiners are permitted to interview the consumers included in the sample and inquire about each subject area listed in the module. The TRID rule is scheduled to go into effect August 1, 2015.