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Financial Services Law Insights and Observations

Amendments and Proposal to TRID Rule Published in Federal Register, Comments Due October 10

Agency Rule-Making & Guidance CFPB TRID RESPA TILA Federal Register

Agency Rule-Making & Guidance

As previously reported in a Special Alert, the CFPB issued amendments to its TILA/RESPA Integrated Disclosure rule, which importantly included a concurrent proposal to address the “black hole” issue that prevents creditors from resetting tolerances using the Closing Disclosure except in very limited circumstances. On August 11, the Bureau published the amendments in a final rule and the proposal in the Federal Register. The final rule takes effect October 10, 2017 with mandatory compliance by October 1, 2018. Comments on the proposal are due October 10, 2017.