TRID – The gift that keeps on giving
For those of you that have been living under the HMDA rock, it is probably a good time to point out that the CFPB recently finalized a few amendments to the TRID rule. Just when you thought we were getting the process down…BAM! Now a lot of these changes are not earth shattering, but they are requirements that we will have to pay attention to none the less. Here are a few key changes:
- Tolerances for the total of payments: Under the finalized amendments the CFPB has added a new tolerance to pay attention to. The “Total of Payments” amount that is disclosed on your Closing Disclosure will now be subject to the same tolerance levels that apply to your finance charge for the purposes of rescission. So under this change the total of payments amount will be considered accurate if it is overstated, or understated by no more than $100.
- Housing assistance lending: Under the original rule there were certain housing assistance programs that were partially exempt from the TRID disclosure requirements, but there was some confusion on if you lost that exemption if the member paid for recording fees and transfer taxes. The recent amendments clarify that those charges can be passed to the member without losing the partial exemptions.