| CFPB's Proposed Amendment to TRID Disclosures Impact Lenders Oh NO MR BILL We are going to hit you on the back side of the head, again 3 working days to Wait for LE, three more to lock, three more for final CD but escrow has to massage the numbers two days so minimum Federal requirement for closing a loan in perfect conditions is nine working days BUT lender has to pay for appraisal re-inspection, any interest rate increases, seller can't give last minute credits, no add ins of repairs at the end. Mine government at work.... or not as the case may be Mr. Bill don't worry we'll get you into a home. Mortgage lenders fear violating the disclosure requirements of the TILA-RESPA Integrated Disclosure Rule ("TRID" or "Rule"). Consumer Financial Protection Bureau ("CFPB") provided informal guidance on certain issues prior to the October 2015 effective date of the Rule, ambiguities in the Rule remain that impact accurate delivery of the Loan Estimate ("LE") and Closing Disclosure ("CD") in connection with applications for closed-end, real estate-secured mortgage loans. The CFPB recognized that regulatory amendments were necessary to memorialize this informal guidance regarding the LE and CD to reduce the risk to lenders of TRID violations. On July 29, 2016, the CFPB issued a Notice of Proposed Rulemaking ("NPRM") to propose a number of amendments to TRID that would formalize certain of its informal guidance and make other technical changes to the Rule. The NPRM does not touch on every issue that industry participants have raised, but it is a step in the right direction, indicating that the CFPB is sensitive to some of the challenges created by the Rule. Although the NPRM does not provide all the cures that lenders would have hoped for, many of the proposals should provide some relief to them. As mortgage industry participants continue to anxiously await the CFPB's final regulations to implement these proposed changes Pray the proposals improve upon the challenges that lenders currently face in providing accurate LEs and CDs to consumers. |