United States

CFPB publishes TRID amendments and proposal


On Aug. 11, 2017, The Consumer Financial Protection Bureau (CFPB) has published the finalized amendments to the TILA/RESPA Integrated Disclosure (TRID) rule as well as a proposal to further amend to the existing rule in the Federal Register. The amendments to the TRID rule consist of the following:

  • Establishes tolerances for the total of payments similar to the existing tolerances regarding finance charges
  • Revises the partial exemption of the integrated disclosure requirements affecting housing finance agencies and nonprofits
  • Revises the existing rule on the application of the integrated disclosure requirements for transactions involving cooperative units
  • Provides guidance on sharing integrated disclosures to various parties involved in the credit transaction

In addition, the final rule provides clarification and technical corrections in various areas of the existing TRID rule. The CFPB has issued an Executive Summary of the 2017 TILA-RESPA Rule highlighting these amendments. Further information regarding the amendments to the TRID rule can be found by reading the Executive Summary of the 2017 TILA - RESPA Rule and the The Bureau of Consumer Financial Protection.

As previously mentioned, along with the amendments to the TRID rule, the CFPB has issued a proposal to amend provisions set forth in the existing rule to address situations in which a Closing Disclosure may be used in determining whether estimated closing costs were disclosed in good faith due to the TRID timing requirements set forth within the existing rule. Further information regarding the proposed rule can be found here.

The effective date of the amendments as well as the deadline to comment on the proposed rule is Oct. 10, 2017. Compliance with the amendments is required by Oct. 1, 2018, for loans in which the credit application is received on or after Oct. 1, 2018 (with the exception of the escrow closing notice and partial payment disclosure requirements as addressed within the final rule).