CFPB Assessment of TRID

On 11/20/19, the CFPB announced a request for public comment on an assessment it will conduct on the TRID rules. 

As part of its assessment, the Bureau intends to address TRID’s effectiveness in meeting the purposes and objectives of the Dodd-Frank Act, the specific goals of the rule, and other relevant factors.  The public is invited to comment on the feasibility and effectiveness of the assessment plan, recommendations to improve the assessment plan, and recommendations for modifying, expanding, or eliminating the TRID Rule, among other questions. 

Specifically, comments are requested on any or all of the following:

1. Comments on the feasibility and effectiveness of the assessment plan, the objectives of

   the TRID Rule that the Bureau intends to use in the assessment, and the outcomes,

   metrics, baselines, and analytical methods for assessing the effectiveness of the Rule as

   described in part IV above;

2. Data and other factual information that the Bureau may find useful in executing its

   assessment plan and answering related research questions, particularly research questions

   that may be difficult to address with the data currently available to the Bureau, as

   described in part IV above;

3. Recommendations to improve the assessment plan, as well as data, other factual

   information, and sources of data that would be useful and available to the Bureau to

   execute any recommended improvements to the assessment plan;

4. Data and other factual information about the benefits and costs of the TRID Rule for

   consumers, creditors, or other stakeholders;

5. Data and other factual information about the effects of the Rule on transparency,

   efficiency, access, and innovation in the mortgage market;

6. Data and other factual information about the Rule’s effectiveness in meeting the purposes

   and objectives of title X of the Dodd-Frank Act (section 1021), which are listed in part IV

   above;

7. Data and other factual information on the disclosure dataset specified in the Assessing

   Firm Effects section above under part IV;

8. Comments on any aspects of the TRID Rule that were or are confusing or on which more

   guidance was or is needed during implementation including whether the issues have been

   resolved or remain unresolved; and

9. Recommendations for modifying, expanding, or eliminating the TRID Rule. Comments are due by January 21, 2020.

The CFPB release can be found here.