CUNA supports the Consumer Financial Protection Bureau’s (CFPB) proposal to remove the 4-business-day limit from its TILA-RESPA integrated disclosure (TRID) rule. The limit dictates, based on timing, the method by which a lender can disclose a revised estimate of closing costs to the borrower.
The CFPB’s proposal is designed to address confusion about the timing requirements for revised disclosures, particularly the Closing Disclosure, for purposes of resetting tolerances.
Specifically, it would amend Regulation Z as it relates to when a creditor may use a Closing Disclosure, instead of a Loan Estimate, to determine if an estimated closing cost was disclosed in good faith and within the permissible tolerance.
The proposed amendments would permit creditors to do so regardless of when the Closing Disclosure is provided relative to consummation.
In its letter, CUNA also requested the CFPB engage in rulemaking and issue guidance to the industry on a frequent basis regarding compliance challenges with the TRID rule.
Additional information, and a link to the letter, can be found on CUNA’s Removing Barriers Blog.