All in TRID

OCC Updates Truth in Lending Act Booklet

Adam Witmer
Regulatory Update, Regulation Z, TRID

On 9/30/2020, the Office of the Comptroller of the Currency rescinded their “Truth in Lending Act” booklet from the Comptroller’s Handbook and instructed examiners to rely on revised interagency procedures. In their release, the OCC explains that the FFIEC has adopted revised interagency examination procedures for the Truth in Lending Act and the revised interagency procedures reflect amendments to Regulation Z published in the Federal Register through May 18, 2018.

CFPB Relief Under Reg Z and TRID Rules

Adam Witmer
Regulatory Update, TRID, Regulation Z

On April 29, 2020, the CFPB took steps to make it easier for consumers with urgent financial needs to obtain access to mortgage credit more quickly in the middle of the COVID-19 pandemic. Specifically, the CFPB has issued an interpretive rule to clarify that consumers can exercise their rights to modify or waive certain required waiting periods under the TILA-RESPA Integrated Disclosure Rule and Regulation Z rescission rules. The Bureau also issued an FAQ document to address when creditors must provide appraisals or other written valuations to mortgage applicants in order to expedite access to credit for consumers affected by the COVID-19 pandemic.

Changing a Lender Credit

Changing a Lender Credit

Adam Witmer
TRID

Adam uses this Compliance Clip (video) to answer this question: can a lender credit change? Adam takes a pretty deep dive answering this question and gives a background of the original TRID rule, talks about TRID 2.0 and, more importantly, the brand new guidance from the CFPB regarding lender credits. This video might be a great training opportunity for your lending staff as it is a sample of what we plan to cover in our upcoming Spring 2020 Quarterly Compliance Update, where we plan to review not just this one FAQ, but all ten new TRID FAQs - so be sure to watch for that program in our store in mid-to-late April.

Expiration Date for Revised Loan Estimates

Expiration Date for Revised Loan Estimates

Adam Witmer
TRID

In this Compliance Clip (video), Adam explains what to do with the expiration date on a revised Loan Estimate after the intent to proceed is received by consumers and provides a background on why there has been confusion in the industry over this minor detail or TRID. If you or your team didn’t catch this change with TRID 2.0 (in 2018), you will want to be sure to catch this video.

Escrow Exemption Threshold for 2020

Adam Witmer
Regulatory Update, TRID

On December 19, 2019, the CFPB announced the annual adjustment to the asset size threshold for small creditors under Regulation Z.  This threshold applies to both the exemption to the requirement to establish an escrow account for higher-priced mortgage loans as well as the thresholds for small creditors to originate small-creditor portfolio and balloon-payment qualified mortgages. For 2020, the exemption threshold has increased from…

CFPB Adds TRID Guidance

Adam Witmer
TRID, Regulatory Update

On 12/18/19, the CFPB released two additional TRID guides regarding disclosures for construction-only and construction-permanent loans. The guidance can be viewed in either a combined guide or a separate guide, and provides examples based on common questions received by the Bureau.

CFPB Assessment of TRID

Adam Witmer
Regulatory Update, 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…

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