TRID Resource Center
Introduction
Welcome to the TRID Resource Center. This center is a one-stop shop for the Know Before You Owe TILA-RESPA Integrated Disclosure (“TRID”) rule issues, providing access to Buckley’s analysis of the TRID rule and the CFPB’s amendments to that rule, transcripts of CFPB webinars providing guidance on the rule, and other CFPB publications that will facilitate implementation of the rule.
Thought Leadership & Analysis
CFPB releases TRID FAQs
On May 14, the CFPB released five new FAQs regarding housing assistance loans to assist with TILA-RESPA Integrated Disclosure Rule (TRID Rule) compliance. Highlights from the FAQs are listed below: The TRID Rule covers a loan if it: “[i] is made by a creditor as defined in § 1026.2(a)(17); [ii] is...
InfoBytesCFPB releases TRID five-year lookback assessment
On October 1, the CFPB released the assessment report required by Section 1022(d) of the Dodd-Frank Act for the TILA-RESPA Integrated Disclosure Rule (TRID), concluding that the TRID Rule “made progress towards several of its goals.” The assessment report was conducted using the Bureau’s own...
InfoBytesCFPB announces e-disclosures and HMDA platform Tech Sprints
On June 29, the CFPB announced two Tech Sprints that will “bring together regulators, technologists, software providers, consumer groups, and financial institutions to develop technological solutions to shared compliance challenges.” As previously covered by InfoBytes , the CFPB announced, in...
InfoBytesCFPB releases TRID factsheet and FAQs
On June 9, the CFPB released a factsheet on TRID Title Insurance Disclosures and FAQs regarding lender credits on the total payments disclosure, the optional signature line, and separating consumer and seller information. Highlights of each document include: TRID Title Insurance Disclosures . The...
InfoBytesCFPB issues TRID interpretive rule, ECOA FAQ
On April 29, the CFPB issued an interpretive rule (IR) “clarifying that consumers can exercise their rights to modify or waive certain required waiting periods” in order to allow borrowers impacted by Covid-19 to access mortgage credit faster. The IR states that if, as a result of the Covid-19...
InfoBytesCFPB releases TRID FAQs
On February 26, the CFPB released 10 new lender credit FAQs to assist with TILA-RESPA Integrated Disclosure Rule (TRID Rule) compliance. Highlights from the FAQs are listed below: “[L]ender credits include [(i)] payments, such as credits, rebates, and reimbursements, that a creditor provides to a...
InfoBytesCFPB releases TRID guidance for construction loans
On December 18, the CFPB published two guides to assist with TILA-RESPA Integrated Disclosure Rule (TRID) compliance for construction-only and construction-permanent loans. The Bureau notes that under Regulation Z, “a creditor may treat a construction-permanent loan as either one, combined...
InfoBytesCFPB seeks feedback on TRID
On November 20, the CFPB issued a request for information (RFI) regarding the TILA-RESPA Integrated Disclosures Rule (TRID Rule) assessment, which is required by Section 1022(d) of the Dodd-Frank Act. Section 1022(d) requires the Bureau to conduct an assessment of each “significant rule or order”...
InfoBytesCFPB releases TRID FAQs on loan estimates
On July 31, the CFPB released FAQs to assist with TILA-RESPA Integrated Disclosure Rule (TRID Rule) compliance. The five new FAQs relate to providing loan estimates to consumers. Highlights include: If a consumer submits the six pieces of information (name, income, social security number, property...
InfoBytesCFPB releases TRID FAQs for construction loans
On May 31, the CFPB released FAQs to assist with TILA-RESPA Integrated Disclosure Rule (TRID) compliance. The two new FAQs relate to the application of TRID to construction loans. Highlights include: Most construction-only and construction-permanent loans are covered by TRID as long as such a loan...
InfoBytesCFPB issues fact sheet on TRID disclosures with assumption transactions
On May 1, the CFPB released a factsheet addressing when loan estimates and closing disclosures are required for assumption transactions under the TILA-RESPA Integrated Disclosure Rule (TRID Rule). The factsheet includes a flowchart and a narrative summary to demonstrate when the disclosures would...
InfoBytesCFPB releases TRID FAQs
On January 25, the CFPB released FAQs to assist with TILA-RESPA Integrated Disclosure Rule (TRID) compliance. Three of the four FAQs relate to corrected closing disclosures and the three business-day waiting period, while the fourth FAQ relates to the use of model forms. Highlights of the FAQs...
InfoBytesFreddie Mac releases various selling updates in Guide Bulletin 2018-19
On October 31, Freddie Mac released Guide Bulletin 2018-19 , which announces selling updates, including updates to the Settlement/Closing Disclosure Statement that sellers are required to use for mortgages with note dates on or after September 25, 2017. Effective immediately, Freddie Mac and Fannie...
InfoBytesOCC updates Comptroller’s Handbook with new TILA booklet
On September 26, the OCC issued Bulletin 2018-31 , which updates the “Truth in Lending Act” (TILA) booklet of the Comptroller’s Handbook , which previously was issued in December 2014. The booklet provides guidance for OCC examiners to be used in connection with the examination and supervision of...
InfoBytesHouse passes bipartisan package of securities and banking bills focusing on capital market regulations
On July 17, the House passed S. 488 , the “JOBS and Investor Confidence Act of 2018” (Act) by a vote of 406 to 4. The package of 32 securities and banking bills now comprises Senate bill S. 488, which previously contained an amendment to the Securities Act Rule 230.701(e) and was included as part...
InfoBytesCFPB finalizes KBYO amendment to address “black hole”
On April 26, the CFPB issued a final amendment to its “Know Before You Owe” mortgage disclosure rule to address when mortgage lenders with a valid changed circumstance or other justification are permitted to reset tolerances and pass on increased closing costs to consumers using the Closing...
InfoBytesSenate passes bipartisan financial regulatory reform bill
On March 14, by a vote of 67-31, the Senate passed the Economic Growth, Regulatory Relief, and Consumer Protection Act (S. 2155) (the bill)—a bipartisan regulatory reform bill crafted by Senate Banking, Housing, and Urban Affairs Committee Chairman Mike Crapo, R-Idaho—that would repeal or modify...
InfoBytesGAO recommends the CFPB review the effectiveness of TRID guidance for small institutions
On February 27, the U.S. Government Accountability Office (GAO) released a report of recommendations to financial regulators on actions to take related to the compliance burdens faced by certain small financial institutions. The report is the result of a study the GAO initiated with over 60...
InfoBytesBuckley Sandler Insights: OMB releases updated and possibly outdated CFPB rulemaking agenda
OMB has released the CFPB’s Fall 2017 rulemaking agenda. Although this is the first update to the agenda since Richard Cordray left the agency in November 2017, delays in the publication of rulemaking agendas are common so the updated agenda may not reflect the views of new CFPB leadership. The...
InfoBytesCFPB Updates Guide to TRID Forms
On December 6, the CFPB published an updated version of the TILA-RESPA Integrated Disclosure Guide to the Loan Estimate and Closing Disclosure Forms. The updated guide reflects the amendments issued by the CFPB on July 7 of this year ( previously covered by a Buckley Sandler Special Alert ). These...
InfoBytesSenate Banking Committee Approves Financial Regulatory Relief Bill
On December 5, the Senate Banking Committee approved bill S. 2155 , Economic Growth, Regulatory Relief, and Consumer Protection Act , which would alter certain financial regulations under the Dodd-Frank Act of 2010. While not as sweeping as previous legislative relief proposals (see previous...
InfoBytesCFPB Publishes Updated TRID Small Entity Compliance Guide; ABA Submits Comments on CFPB’s Proposal to Fix TRID’s “Black Hole” Issue
On October 6, the CFPB released an updated version of its TILA-RESPA Integrated Disclosure Rule (Final Rule) small entity compliance guide . The updated guide reflects amendments issued July 7, previously discussed in a Buckley Sandler Special Alert , that the CFPB made to the Final Rule. The guide...
InfoBytesIllinois Governor Enacts Amendments to Predatory Lending Database Article
On September 15, Illinois Governor Bruce Rauner signed into law amendments to the state’s Residential Real Property Disclosure Act to change provisions under its Predatory Lending Database Article. Public Act 100-0509 sets forth the following changes, among others: (i) certificates of compliance or...
InfoBytesCFPB Issues Summary of Changes and Clarifications to 2017 TILA-RESPA Rule
On August 30, the CFPB released “ 2017 TILA-RESPA Rule: Detailed Summary of Changes and Clarifications ” to assist the mortgage industry in implementing the disclosure requirements of the CFPB’s recently finalized TILA-RESPA Rule. The summary provides an in-depth outline of modifications to the...
InfoBytesAmendments and Proposal to TRID Rule Published in Federal Register, Comments Due October 10
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...
InfoBytesSpecial Alert: CFPB Finalizes Amendments to Know Before You Owe/TRID Rule and Proposes Additional Changes to Address “Black Hole”
On Friday, the CFPB issued amendments to the KBYO/TRID rule . The Bureau billed the changes as clarifying and technical in nature but stated that the final rule “also makes a limited number of additional substantive changes where the Bureau has identified discrete solutions to specific...
ArticlesEleventh Circuit Rules that Return of a Certified Mail Receipt Satisfies Regulation X of RESPA
In a per curiam opinion issued on March 1, 2017, the Eleventh Circuit Court of Appeals affirmed the dismissal of a complaint alleging that a mortgage servicer had violated Regulation X of the Real Estate Settlement Procedures Act (“RESPA”) by failing to “correctly or timely acknowledge receipt of...
InfoBytesFHFA Director Appeared Before the Senate Banking Committee on May 11; Discussed Fannie/Freddie, Proposed "Underserved Markets Plans"
On May 11, the Senate Committee on Banking, Housing, and Urban Affairs met in open session at 10:00 a.m. to discuss “The Status of the Housing Finance System After Nine Years of Conservatorship.” Federal Housing Finance Agency (FHFA) Director Mel Watt was the only witness scheduled to testify. The...
InfoBytesGov. Cuomo Announces New Title Insurance Regulations Target Business Gifts, Ancillary Fees and Transactions with Affiliates
On May 1, New York Governor Andrew M. Cuomo announced two new proposed regulations to “crack down on unscrupulous practices in the title insurance industry.” According to the Governor, the proposed measures were drafted in response to an investigation by the state Department of Financial Services...
InfoBytesFollowing Hearing, House Financial Services Committee Chairman Formally Introduces Financial CHOICE Act of 2017
On April 26, the House Financial Services Committee held a hearing to discuss The Financial CHOICE Act – a GOP proposal to “reform the financial regulatory system” that was initially introduced and considered, though differing in a number of respects from the current version, but not adopted in the...
InfoBytesFDIC Releases Third Volume in its Affordable Mortgage Lending Guide
On April 6, the FDIC released the third volume of its Affordable Mortgage Lending Guide ( Guide ). The Guide is designed to help community bankers understand and compare various affordable mortgage-related programs, as well as their Community Reinvestment implications. This third installment of the...
InfoBytesSpecial Alert: President Signs Executive Order Calling For Review of Financial Regulations
On February 3, President Trump signed an executive order (the Executive Order) directing the Treasury Secretary and the heads of the member agencies of the Financial Stability Oversight Council (FSOC) to review financial laws and regulations—including the Dodd-Frank Act and regulations implementing...
InfoBytesCFPB Mortgage Servicing Rule Published in Federal Register
Last week, the CFPB’s final rule amending the mortgage servicing provisions of Regulations X and Z was published in the Federal Register . The amendments were previously covered in BuckleySandler’s August 9 Special Alert . The majority of the final rule will take effect on October 19, 2017, exactly...
InfoBytesSpecial Alert: CFPB Proposes Amendments to Know Before You Owe/TRID Rule
On Friday, the CFPB issued its much anticipated proposal to amend the KBYO/TRID rule. The CFPB crowded dozens of proposed changes into the almost 300 page proposal, most of which are highly technical and require careful examination. As the Bureau has signaled since its intention to issue amendments...
InfoBytesSpecial Alert: CFPB Plans to Propose TRID Amendments in July
Director Cordray announced yesterday in a letter to industry trade groups that the CFPB has "begun drafting a Notice of Proposed Rulemaking (NPRM) on the Know Before You Owe Rule.” However, contrary to some reports, the proposal is not imminent. Instead, Director Cordray stated that the Bureau “...
InfoBytesSpecial Alert: CFPB Director Opines on TRID Liability
On December 29, 2015, CFPB Director Richard Cordray issued a letter in response to concerns raised by the Mortgage Bankers Association regarding violations of the CFPB’s new TILA-RESPA Integrated Disclosure (“TRID”) rule, also known as the Know Before You Owe rule. In an effort to address concerns...
InfoBytesSpecial Alert: CFPB Officially Delays TRID Rule Until October 3
The CFPB finalized a rule today that delays the effective date of the TILA-RESPA Integrated Disclosure (“TRID”) rule, including all amendments, from August 1 to October 3, 2015 . This is consistent with the proposed rule issued last month, which we wrote about here . The CFPB considered...
InfoBytesSpecial Alert: CFPB Issues Proposal to Delay TRID Rule Until October 3
The CFPB issued a proposed rule today to delay the effective date of the TILA-RESPA Integrated Disclosure (“TRID”) rule, including all amendments, from August 1 to October 3, 2015 . The proposed delayed effective date is two days later than the date announced last week so that the effective date...
InfoBytesSpecial Alert: CFPB Will Propose to Delay TRID Rule Until October 1
Two weeks after declining requests from industry and members of Congress for delayed enforcement of the TILA-RESPA Integrated Disclosure (“TRID”) rule, the CFPB announced today that it will be issuing a proposed amendment to delay the rule’s effective date from August 1 to October 1, 2015. CFPB...
InfoBytesSpecial Alert: CFPB Issues Statement on TRID Enforcement
On June 3, CFPB Director Cordray responded to requests from industry and members of Congress for delayed enforcement of the Bureau’s TILA-RESPA Integrated Disclosure (“TRID”) rule, which will take effect for applications received on or after August 1, 2015. The Bureau did not, as many had hoped,...
InfoBytesSpecial Alert: Proposed Amendments to the TRID Rule and Introducing Buckley's TRID Resource Center
Buckley is pleased to announce our new TILA-RESPA Integrated Disclosure (“TRID”) Resource Center . The TRID Resource Center is a one-stop shop for TRID issues, providing access to Buckley's analysis of the TRID rule and the CFPB’s amendments, transcripts of CFPB webinars providing guidance on the...
ArticlesSpecial Alert: CFPB Finalizes Rule Combining TILA and RESPA Mortgage Disclosures
UPDATED OCTOBER 14, 2014: Updated to reflect amendments proposed by the CFPB on October 10, 2014. On November 20, 2013, the CFPB finalized its long-awaited rule combining the mortgage disclosures consumers receive under the Truth in Lending Act (“TILA”) and the Real Estate Settlement Procedures Act...
InfoBytesSpecial Feature: New CFPB Proposed Rule Combining TILA/RESPA Disclosures
After years of discussion and analysis by industry groups, consumer advocates, regulators, and Congressional committees, the Consumer Financial Protection Bureau ("CFPB") has finally proposed a rule (the "Proposed Rule" or "Rule") that merges the Truth in Lending Act ("TILA") and Real Estate...
InfoBytes
Regulatory Resources
TRID Final Rule & Amendments
- Amendments I
- October 2014 Proposed Amendments (79 Fed. Reg. 64336)
- February 2015 Final Amendments (80 Fed. Reg. 8767)
- Delayed Effective Date
- Correction
- Amendments II
- July 2016 Proposed Amendments (81 Fed. Reg. 54317)
- August 2017 Final Amendments (82 Fed. Reg. 37656)
- Amendments III
CFPB Guidance & Resources
- Webinars and Transcripts
- Webinar Question Index
- April 2016 Post-Effective Date Questions and Guidance
- March 2016 Construction Lending
- May 2015 Common Questions
- November 2014 Completing the Closing Disclosure
- October 2014 Frequently Asked Questions Regarding the Loan Estimate
- August 2014 Frequently Asked Questions Regarding Operational Requirements
- June 2014 Overview of the Rule (recording only)
- Written Guidance and Sample Forms
- Updated TILA-RESPA Integrated Disclosure FAQs (June 9, 2020)
- Factsheet: TRID Title Insurance Disclosures
- Guide for separate construction and permanent phase disclosures
- Guide for combined, one-transaction disclosures
- 2017 Amendments - CFPB's Detailed Summary of Changes
- Guide to loan estimate and closing disclosure forms - Version 2.1
- Guide to loan estimate and closing disclosure forms - Version 1.5
- January 2016 KBYO Mortgage Disclosures and Construction Loans
- July 2015 TILA-RESPA Integrated Disclosure Timeline Example (version 2.0)
- June 2015 Closing Factsheet: Will the new mortgage disclosures delay my closing?
- Sample Forms (scroll down to "Forms")
- Small entity compliance guide - Version 5.2
- Small entity compliance guide - Version 4.1
- Resources
- September 2015 CFPB Dodd-Frank Mortgage Rules Readiness Guide (version 4.0)
- September 2015 TILA Integrated Disclosure Examination Procedures
- August 2015 Your Home Loan Toolkit: A step-by-step guide
- January 2014 Consumer Handbook on Adjustable-Rate Mortgages (CHARM Booklet)
- Guide for Real Estate Professionals
- Guide for Settlement Professionals
- Find a Housing Counselor
- CFPB TRID FAQs
- Other Materials
- April 2016 CFPB Letter to Industry Trades on Planned Amendments
- December 2015 CFPB Letter to MBA on Liability for Errors
- September 2014 CFPB Director Cordray Remarks to NAFCU
- November 2013 Final Rule Press Release
- November 2013 Blog: A Final Rule That Makes Mortgage Disclosure Better for Consumers
- November 2013 Summaries of Final Rule
- November 2013 Explainer: How the final TILA-RESPA rule differs from the proposal
- November 2013 Testing Factsheet
Other Agency & GSE Guidance
- March 2016 FHA Letter on Certifications
- October 2015 FHA Letter on Errors
- October 2015 Freddie Mac Letter on Errors
- October 2015 Fannie Mae Lender Letter LL-2015-06 on Errors
- October 2015 FDIC Financial Institution Letter FIL-43-2015 on Errors
- October 2015 Federal Reserve Consumer Affairs Letter CA 15-10 on Errors