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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.
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