The Bureau of Consumer Financial Protection (CFPB) has finalized its July 2017 proposed amendments to the Truth in Lending Act/Real Estate Settlement Procedures Act integrated disclosure (TRID) rule.
The amendments are designed to address the TRID “black hole,” which occurs when the lender has provided a borrower with the Closing Disclosure, and then a fee increase occurs.
Currently, a creditor may only use a Closing Disclosure to reset tolerances if there are fewer than four business days between the time the creditor is required to provide the Closing Disclosure reflecting the revised estimate and consummation.
Credit unions and other creditors can often be forced to absorb these increased costs that would otherwise be rightfully passed on to the member but for the four-day limit rule.
continue reading »