For years, financial institutions have struggled with how to disclose the expiration date for disclosed fees on a Loan Estimate when a new Loan Estimate is issued.  Well, the latest revision of TRID has clarified this for us, and it is probably not what you expected to hear.

While logic would tell us that a definition should be consistent from one regulation to another, reality tells us that this is anything but the truth.  When I teach compliance schools where we work through regulations from top to bottom, I always make an effort to point out the difference in the definition of “business day” as the definition varies - sometimes greatly - from one regulation to another.  In fact, Regulation Z actually has two different definitions for business day: the precise definition and the general definition.

Construction loans have proven to be anything but simple under TRID.  The CFPB gave very limited guidance for construction loans first came out and much of the guidance they have provided isn’t as clear as it should be.  For this reason, many financial institutions still seem to struggle with TRID disclosures for construction loans.  For example, disclosing the correct “Product” for a construction loans can

Construction loans under TRID have proven to be very challenging for many community banks and credit unions.  The reason for this is twofold: the CFPB did not provide much guidance in regards to construction loans and the guidance that they did provide is often found to be confusing.  For this reason, it is worth revisiting the TRID rules for construction loans every once in a while.  I recently received a question regarding the purpose field on the Loan Estimate (LE) as well as the Closing Disclosure (CD) for single-close, two phase construction loan where the land was