news.cuna.org/articles/116411-compliance-cfpb-issues-updated-trid-rule-faqs

Compliance: CFPB issues updated TRID rule FAQs

August 12, 2019

The Consumer Financial Protection Bureau released an updated frequently asked questions document on its Truth in Lending Act-Real Estate Settlement Procedures Act integrated disclosure (TRID) rule. The document was previously updated in May.

Though the questions and answers in the document are intended to aid compliance with TRID, the CFPB notes that reviewing the document is “not a substitute for reviewing the Truth in Lending Act, the Real Estate Settlement Procedures Act, Regulation Z or its official interpretations, which the bureau notes are the “definitive sources of information regarding the requirements.

Information included in the update includes answers to the following questions:

  • When is a creditor required to provide a Loan Estimate to a consumer?
  • Can creditors require consumers to provide additional information (other than the six pieces of information that constitute an application under the TRID Rule) in order to receive a Loan Estimate?
  • Can creditors require consumers to submit verifying documents in order for the consumer to receive a Loan Estimate?
  • Is the requirement to provide a Loan Estimate triggered if the consumer submits the six pieces of information in order to receive a pre-approval or pre-qualification letter?
  • What if a creditor needs to collect additional information (other than the six pieces of information that constitute an application for purposes of the TRID Rule) or verifying documents to process a pre-approval or pre-qualification request?

In addition to the CompBlogCUNA’s Compliance Community contains discussion boards and a number of other resources for credit union compliance professionals around the country.