CFPB News: CFPB Releases Changes to TRID
By TLTA Staff
July 12, 2017
As we reported in TLTA's Breaking News
alert on Monday, June 10, the CFPB released updated changes to the TRID rule
late on Friday, June 7. This rule has been in the process of being updated since July 2016, when CFPB first issued this rule for comment. TLTA commented
on CFPB's proposals at the time, noting that the bureau did not address the simultaneous issue problem. The agency received more than 1,600 comments, and the resulting new changes are over 560 pages long. The effective date for mandatory compliance will be Oct. 1, 2018, but the new rules will technically be effective 60 days after publication in the Federal Register, which will come within a few weeks.
The changes specifically relate to the practical implementation of TRID. When the rulemaking changes were released last July, the bureau did not reopen any major policy decisions. It stated when releasing the final proposal that it was "prioritizing its resources to further facilitate industry's implementation progress. This final rule does not contain any revisions that implicate fundamental policy choices, such as the disclosure of simultaneous issuance title insurance premiums made in the TILA-RESPA Final Rule. This final rule also does not include additional cure provisions." We are disappointed with the CFPB's decision not make changes to the simultaneous issue concern, but not surprised because they openly stated they would not. We think possible changes could come when a new director of the CFPB comes into office and takes a fresh look at the issue, but nothing is guaranteed. CFPB director Richard Cordray's term will end in July 2018.
In an ALTA Advocacy Update, ALTA CEO Michelle Korsmo noted, "On sharing the Closing Disclosure, there is extensive discussion of the comments and the interplay between Gramm-Leach-Bliley Act (GLBA) and state law. The rule does not go so far as to mandate sharing. Instead, it states, 'the Bureau notes that such sharing of the Closing Disclosure may be permissible currently to the extent that it is consistent with GLBA and Regulation P and is not barred by applicable State law. However, the Bureau does not believe that expansion of the scope of such permissible sharing would, in this rulemaking, be germane to the purposes of Regulation Z.'"
Read the TLTA Breaking News Alert »
Read the CFPB Press Release »
Read the CFPB Executive Summary »
Read the Final Rule Amendments »