October 7, 2020
In This Issue:
- TLTA Federal Report: CFPB Releases Its Five-Year Assessment of TRID Rule
- TLTA Advocacy Update: TDI Grants Request for Extension of Modified Requirements for Sworn Statements to Dec. 31, 2020
- It's Official – Institute Is Going Virtual! New Dates: Dec. 7-9
- FHFA Attempts to Improve the Real Estate Experience for Korean, Vietnamese and Filipino Borrowers
- U.S. Treasury Warns Cyber Insurers' Payments to Hackers May Violate Sanctions
TLTA Federal Report: CFPB Releases Its Five-Year Assessment of TRID Rule
James E. Hyland, TLTA Federal Legislative Counsel | Oct. 6, 2020
Last week, the CFPB released its five-year “assessment” of the TRID rule – a report over 300 pages long. The Dodd-Frank Act requires the CFPB to conduct an assessment of each significant rule and publish a report within five years. CFPB issued the TRID Rule in November 2013, and the rule took effect on Oct. 3, 2015.
As background, TLTA filed comments on the CFPB’s assessment in January of 2020. In July, TLTA leadership held a phone conference with the CFPB authors and discussed the impact of TRID on our industry. In early August, TLTA filed an additional set of comments with CFPB based on member surveys, with an emphasis on the confusion related to how simultaneous issue is disclosed to consumers.
CFPB did acknowledge our industry’s comments on the confusing nature of the disclosure of simultaneous issue of an owners and lenders title. As it noted, many commenters, especially trade groups and commenters associated with the title insurance industry, stated the rule’s calculation for the disclosure of simultaneous title insurance policy premiums is inaccurate and confusing to consumers. A trade association representing title companies provided a study of consumers that it stated showed consumers reacted negatively to the rule’s prescribed calculation. Some commenters stated that the rule should be amended to permit rate calculations established by state law, or to only require the state law calculations.
In a preamble to the CFPB assessment and the five-year look back, Director Kraninger said that “this places a responsibility on the Bureau to take a hard look at each significant rule it issues and evaluate whether the rule is effective.” Ironically, she further stated that “despite our best efforts, the Bureau was unable to obtain or generate the data necessary to do such [cost benefit] analysis of the TRID Rule.”
This will not be the final say on TRID; according to her, “its issuance is not the end of the agency’s mortgage disclosure work. The Bureau is interested in hearing reactions from stakeholders to the report’s findings and conclusions.”
Read More of TLTA's Analysis »
Read the Cover Letter for TLTA's CFPB Submission on Closing Disclosure »
Review a Summary of TLTA's Closing Disclosure Survey Responses »
TLTA Advocacy Update: TDI Grants Request for Extension of Modified Requirements for Sworn Statements to Dec. 31, 2020
TLTA | Oct. 5, 2020
On Wednesday, Sept. 30, TDI announced that the window of time during which the financial and licensing filings identified in the modified filings chart could be submitted without sworn statements, affidavits and notarization was further extended from Sept. 30 to Dec. 31.
TLTA requested this extension, and we remain grateful for TDI's ongoing commitment to providing coronavirus-related regulatory relief during these unprecedented times.
Title Agent / Escrow Officer Annual Audit of Trust Fund Accounts, Licensing Forms
Review the filings that can be submitted without sworn statements, affidavits and notarizations. If you have questions about title agent and escrow officer licensing filings, please email TDI-TitleLicensing@tdi.texas.gov
Corporate and Financial Filing
Review the filings that can be submitted without sworn statements, affidavits and notarizations. If you have questions about financial filing requirements, please email FIN-GM@tdi.texas.gov
It's Official – Institute Is Going Virtual! New Dates: Dec. 7-9
TLTA | Oct. 5, 2020
Thank you for your patience as we weighed all the considerations and determined the best way to deliver our time-honored Institute program to you during these unique times – we're going virtual! Designed for real estate attorneys, agency owners and advanced closers, the Texas Land Title Institute continues to be the go-to educational resource for advanced title professionals working to master some of our industry's most complicated challenges. The TLTA Institute Committee has developed another outstanding program this year, and we look forward to bringing it to you in a virtual format, which includes these must-have features:
Review the Schedule »
Register Now »
- Same Great, Deep Dive Program
- Lower Price for Virtual Format
- Three, Half-Day Schedules Leave Time to Do Business in the Afternoons
- Each Day Capped with Luncheon Session Featuring Special Speakers
- Live Chat During Scheduled Sessions
- Registrants Provided On-Demand Access to All Sessions Through Jan. 15, 2021
- MCLE, CE Hours Available
- Virtual Networking
FHFA Attempts to Improve the Real Estate Experience for Korean, Vietnamese and Filipino Borrowers
Mortgage Professional American | Oct. 2, 2020
On Sept. 30, the Federal Housing Finance Agency, Fannie Mae and Freddie Mac announced that they would be adding Vietnamese, Korean and Tagalog language resources to the Mortgage Translations Clearinghouse, a collection of translated documents and tools intended to help lenders, servicers and others involved in the mortgage process better assist borrowers with limited English proficiency (LEP).
Launched in 2018, the Clearinghouse was first populated with Spanish and traditional Chinese resources. With the addition of documents printed in Korean, Tagalog and Vietnamese, the FHFA now has assistance in place for speakers of the five most common non-English languages spoken by LEP households in the U.S.
Read More »
U.S. Treasury Warns Cyber Insurers' Payments to Hackers May Violate Sanctions
Reuters | Oct. 1, 2020
Cyber insurers and other financial institutions that facilitate payments to hackers to end cyberattacks risk running afoul of sanctions rules, the U.S. Treasury Department warned on Thursday.
The warnings, which referenced malicious programs known as ransomware, came in advisories from Treasury's Office of Foreign Assets Control (OFAC) and Financial Crimes Enforcement Network (FinCEN).
Read More »
Read OFAC's Advisory »
Read FinCEN's Advisory »
Learn More About National Cybersecurity Awareness Month »
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