Exception Tracking Spreadsheet (TicklerTrax™)
Downloaded by more than 1,000 bankers. Free Excel spreadsheet to help you track missing and expiring documents for credit and loans, deposits, trusts, and more. Visualize your exception data in interactive charts and graphs. Provided by bank technology vendor, AccuSystems. Download TicklerTrax for free.
CFPB finalizes update to TRID rule
The CFPB announced on Friday a final rule updating its "Know Before You Owe" mortgage disclosure rule (a/k/a the TILA-RESPA Integrated Disclosure or TRID rule) with amendments that are intended to formalize guidance on the rule, and provide greater clarity and certainty. The CFPB is also releasing a limited follow-up proposal to address an additional implementation issue.
In addition to the clarifications and technical corrections, the final rule amendments also address other issues, including:
- Tolerance provisions for the total of payments that parallel the tolerances for the finance charge and disclosures affected by the finance charge
- Adjustments to expand the provision granting a partial exemption from disclosure requirements of certain housing assistance loans
- Extension of the rule's coverage to all cooperative units
- Provisions allowing the sharing disclosures with real estate brokers and other agents, and clarifying how a creditor may provide separate disclosure forms to the consumer and a seller.
The final rule will be effective 60 days after it is published in the Federal Register, with compliance optional (except for compliance with the amended escrow cancellation notice requirement under § 1026.20(e) and the partial payment policy disclosure requirement under § 1026.39(d)(5)) for any application received before October 1, 2018. Compliance will be mandatory for any application received on or after October 1, 2018, and for all loans with respect to the amended escrow cancellation notice and disclosure of partial payment policy beginning October 1, 2018.
UPDATE: The final rule was published at https://www.federalregister.gov/d/2017-15764 in the 8/11/2107 Federal Register, with an October 10, 2017, effective date. See above for the mandatory compliance date.
The CFPB is also issuing a proposal addressing when a creditor may use a Closing Disclosure or corrected Closing Disclosure, instead of a Loan Estimate, to determine if an estimated closing cost was disclosed in good faith and within tolerance. Apparently, the changes in this area included in its 2016 proposal were interpreted in two very different ways. Comments on the revised proposal will be due 60 days after its publication in the Federal Register.
UPDATE: The proposal was published at https://www.federalregister.gov/d/2017-15763 in the 8/11/2017 Federal Register, with a comment period ending October 10, 2017.