United States

Changes to TILA RESPA integrated disclosures final rule


On Oct. 10, 2014, the Consumer Financial Protection Bureau (CFPB) proposed several modifications to the TILA-RESPA Integrated Disclosures (TRID) rule that becomes effective on Aug. 1, 2015. The proposal was finalized by the CFPB on Jan. 20, 2015, and published in the Federal Register on Feb. 19, 2015, and is also effective on Aug. 1, 2015, for applications received on or after that date. It modified the TRID rule in the following four ways:

  • Extends the time creditors have to provide a revised Loan Estimate when applicants lock an interest rate or extend a rate lock after the Loan Estimate has been provided. In the original rule, creditors were required to provide a revised Loan Estimate on the same day that the interest rate was locked. The amendment permits additional time to provide the revised Loan Estimate. Under the revised rule, creditors have three business days after the rate is locked to provide the revised Loan Estimate.
  • Updates the Loan Estimate to include language informing the consumer that the consumer may receive a revised Loan Estimate if the loan takes more than 60 days to settle. This applies in instances involving construction loans for new construction where the creditor anticipates settlement will occur more than 60 days after the Loan Estimate was issued. By including the language on the Loan Estimate, the creditor reserves the right to issue a revised Loan Estimate any time prior to 60 days before consummation.
  • Revises the final rule to require that the loan originator's name and NMLSR ID be included on the Loan Estimate and Closing Disclosure.
  • Changes involving nonsubstantive updates to the regulation, including updates to wording, corrected citations and cross-references in the regulation and commentary.